Privacy management systems and methods

ABSTRACT

Data processing systems and methods, according to various embodiments, are adapted for mapping various questions regarding a data breach from a master questionnaire to a plurality of territory-specific data breach disclosure questionnaires. The answers to the questions in the master questionnaire are used to populate the territory-specific data breach disclosure questionnaires and determine whether disclosure is required in territory. The system can automatically notify the appropriate regulatory bodies for each territory where it is determined that data breach disclosure is required.

CROSS-REFERENCE TO RELATED APPLICATIONS

This application is a continuation-in-part of U.S. patent applicationSer. No. 17/139,650, filed Dec. 31, 2020, which is a continuation ofU.S. patent application Ser. No. 16/808,503, filed Mar. 4, 2020, nowU.S. Pat. No. 10,885,485, issued Jan. 5, 2021, which claims priorityfrom U.S. Provisional Patent Application Serial No. 62/813,584, filedMar. 4, 2019, and is also a continuation-in-part of U.S. patentapplication Ser. No. 16/714,355, filed Dec. 13, 2019, now U.S. Pat. No.10,692,033, issued Jun. 23, 2020, which is a continuation of U.S. patentapplication Ser. No. 16/403,358, filed May 3, 2019, now U.S. Pat. No.10,510,031, issued Dec. 17, 2019, which is a continuation of U.S. patentapplication Ser. No. 16/159,634, filed Oct. 13, 2018, now U.S. Pat. No.10,282,692, issued May 7, 2019, which claims priority from U.S.Provisional Patent Application Ser. No. 62/572,096, filed Oct. 13, 2017and U.S. Provisional Patent Application Ser. No. 62/728,435, filed Sep.7, 2018, and is also a continuation-in-part of U.S. patent applicationSer. No. 16/055,083, filed Aug. 4, 2018, now U.S. Pat. No. 10,289,870,issued May 14, 2019, which claims priority from U.S. Provisional PatentApplication Ser. No. 62/547,530, filed Aug. 18, 2017, and is also acontinuation-in-part of U.S. patent application Ser. No. 15/996,208,filed Jun. 1, 2018, now U.S. Pat. No. 10,181,051, issued Jan. 15, 2019,which claims priority from U.S. Provisional Patent Application Ser. No.62/537,839, filed Jul. 27, 2017, and is also a continuation-in-part ofU.S. patent application Ser. No. 15/853,674, filed Dec. 22, 2017, nowU.S. Pat. No. 10,019,597, issued Jul. 10, 2018, which claims priorityfrom U.S. Provisional Patent Application Ser. No. 62/541,613, filed Aug.4, 2017, and is also a continuation-in-part of U.S. patent applicationSer. No. 15/619,455, filed Jun. 10, 2017, now U.S. Pat. No. 9,851,966,issued Dec. 26, 2017, which is a continuation-in-part of U.S. patentapplication Ser. No. 15/254,901, filed Sep. 1, 2016, now U.S. Pat. No.9,729,583, issued Aug. 8, 2017, which claims priority from: (1) U.S.Provisional Patent Application Ser. No. 62/360,123, filed Jul. 8, 2016;(2) U.S. Provisional Patent Application Ser. No. 62/353,802, filed Jun.23, 2016; and (3) U.S. Provisional Patent Application Ser. No.62/348,695, filed Jun. 10, 2016. The disclosures of all of the abovepatent applications are hereby incorporated herein by reference in theirentirety.

TECHNICAL FIELD

This disclosure relates to a data processing system and methods forretrieving data regarding a plurality of privacy campaigns, and forusing that data to assess a relative risk associated with the dataprivacy campaign, provide an audit schedule for each campaign, andelectronically display campaign information.

BACKGROUND

Over the past years, privacy and security policies, and relatedoperations have become increasingly important. Breaches in security,leading to the unauthorized access of personal data (which may includesensitive personal data) have become more frequent among companies andother organizations of all sizes. Such personal data may include, but isnot limited to, personally identifiable information (PII), which may beinformation that directly (or indirectly) identifies an individual orentity. Examples of PII include names, addresses, dates of birth, socialsecurity numbers, and biometric identifiers such as a person'sfingerprints or picture. Other personal data may include, for example,customers' Internet browsing habits, purchase history, or even theirpreferences (e.g., likes and dislikes, as provided or obtained throughsocial media).

Many organizations that obtain, use, and transfer personal data,including sensitive personal data, have begun to address these privacyand security issues. To manage personal data, many companies haveattempted to implement operational policies and processes that complywith legal requirements, such as Canada's Personal InformationProtection and Electronic Documents Act (PIPEDA) or the U.S.'s HealthInsurance Portability and Accountability Act (HIPPA) protecting apatient's medical information. Many regulators recommend conductingprivacy impact assessments, or data protection risk assessments alongwith data inventory mapping. For example, the GDPR requires dataprotection impact assessments. Additionally, the United Kingdom ICO'soffice provides guidance around privacy impact assessments. The OPC inCanada recommends certain personal information inventory practices, andthe Singapore PDPA specifically mentions personal data inventorymapping.

In implementing these privacy impact assessments, an individual mayprovide incomplete or incorrect information regarding personal data tobe collected, for example, by new software, a new device, or a newbusiness effort, for example, to avoid being prevented from collectingthat personal data, or to avoid being subject to more frequent or moredetailed privacy audits. In light of the above, there is currently aneed for improved systems and methods for monitoring compliance withcorporate privacy policies and applicable privacy laws in order toreduce a likelihood that an individual will successfully “game thesystem” by providing incomplete or incorrect information regardingcurrent or future uses of personal data.

Organizations that obtain, use, and transfer personal data often workwith other organizations (“vendors”) that provide services and/orproducts to the organizations. Organizations working with vendors may beresponsible for ensuring that any personal data to which their vendorsmay have access is handled properly. However, organizations may havelimited control over vendors and limited insight into their internalpolicies and procedures. Therefore, there is currently a need forimproved systems and methods that help organizations ensure that theirvendors handle personal data properly.

Many organizations offer multiple services to customers and other users.Because each such service may use personal data (e.g., collect personaldata, store personal data, retain personal data, etc.) across manydifferent jurisdictions, the risks posed by a potential data breachrelated to those services may be great. Moreover, the geographicallocation of users of such services may vary, which may also affect theresponse requirements that may apply to a data breach in differentjurisdictions. Therefore, there is currently a need for improved systemsand methods of for handling intrusions or errors that lead to anexposure of data.

SUMMARY

A method, in various embodiments, comprises: (1) determining, bycomputing hardware, data breach response requirements for each affectedjurisdiction for a data breach; (2) obtaining, by the computinghardware, data breach response prioritization data; (3) generating, bythe computing hardware and based on evaluating the data breach responserequirements against the data breach response prioritization data, agraphical user interface by configuring a first navigation element onthe graphical user interface and excluding a second navigation elementfrom the graphical user interface; (4) transmitting, by the computinghardware, a first instruction to a user device to present the graphicaluser interface on the user device; (5) detecting, by the computinghardware, a selection of a first navigation element; and (6) in responseto detecting the selection of the first navigation element,transmitting, by the computing hardware, a second instruction to theuser device causing the user device to retrieve and present a firstdisplay element on the user device. In particular embodiments: (1) thefirst navigation element is configured for navigating to a first displayelement that presents a first data breach response requirement, and (2)the second navigation element is configured for navigating to a seconddisplay element that presents a second data breach response requirement.

In particular embodiments, a system comprises a non-transitorycomputer-readable medium storing instructions; and processing hardwarecommunicatively coupled to the non-transitory computer-readable medium.In various embodiments, the processing hardware is configured to executethe instructions and thereby perform operations comprising: (1)identifying data breach data and affected jurisdictions for a databreach; (2) determining data breach response requirements for each ofthe affected jurisdictions based on the data breach data; (3) obtainingdata breach response prioritization data; (4) generating a response planfor the data breach by evaluating the data breach response requirementsagainst the data breach response prioritization data; (5) generating,based on the response plan, a graphical user interface by configuring afirst set of navigation elements on the graphical user interface andexcluding a second set of navigation elements from the graphical userinterface, wherein: (A) each respective navigation element of the firstset of navigation elements is configured for navigating to a differentrespective display element that presents a first different respectivedata breach response requirement, and (B) each respective navigationelement of the second set of navigation elements is configured fornavigating to a different respective display element that presents asecond different respective data breach response requirement, and; (6)transmitting a first instruction to a user device to present thegraphical user interface on the user device; (7) detecting a selectionof a first navigation element of the first set of navigation elements;and (8) in response to detecting the selection of the first navigationelement, transmitting a second instruction to the user device causingthe user device to retrieve and present the respective display elementfor the first navigation element on the user device.

In still other embodiments, a system comprises a non-transitorycomputer-readable medium storing instructions; and processing hardwarecommunicatively coupled to the non-transitory computer-readable medium.In various embodiments, the processing hardware is configured to executethe instructions and thereby perform operations comprising: (1)identifying data breach data and affected jurisdictions for a databreach; (2) determining data breach response requirements for each ofthe affected jurisdictions based on the data breach data; (3) obtainingdata breach response prioritization data; (4) generating a response planfor the data breach by evaluating the data breach response requirementsagainst the data breach response prioritization data; and (5) causingperformance of one of the data breach response requirements according tothe response plan.

The details of one or more embodiments of the subject matter describedin this specification are set forth in the accompanying drawings and thedescription below. Other features, aspects, and advantages of thesubject matter may become apparent from the description, the drawings,and the claims.

BRIEF DESCRIPTION OF THE DRAWINGS

Various embodiments of a system and method for operationalizing privacycompliance and assessing risk of privacy campaigns are described below.In the course of this description, reference will be made to theaccompanying drawings, which are not necessarily drawn to scale, andwherein:

FIG. 1 is a diagram illustrating an exemplary network environment inwhich the present systems and methods for operationalizing privacycompliance may operate.

FIG. 2 is a schematic diagram of a computer (such as the server 120; oruser device 140, 150, 160, 170, 180, 190; and/or such as the vendor riskscanning server 1100, or one or more remote computing devices 1500) thatis suitable for use in various embodiments;

FIG. 3 is a diagram illustrating an example of the elements (e.g.,subjects, owner, etc.) that may be involved in privacy compliance.

FIG. 4 is a flow chart showing an example of a process performed by theMain Privacy Compliance Module.

FIG. 5 is a flow chart showing an example of a process performed by theRisk Assessment Module.

FIG. 6 is a flow chart showing an example of a process performed by thePrivacy Audit Module.

FIG. 7 is a flow chart showing an example of a process performed by theData Flow Diagram Module.

FIG. 8 is an example of a graphical user interface (GUI) showing adialog that allows for the entry of description information related to aprivacy campaign.

FIG. 9 is an example of a notification, generated by the system,informing a business representative (e.g., owner) that they have beenassigned to a particular privacy campaign.

FIG. 10 is an example of a GUI showing a dialog allowing entry of thetype of personal data that is being collected for a campaign.

FIG. 11 is an example of a GUI that shows a dialog that allowscollection of campaign data regarding the subject from which personaldata was collected.

FIG. 12 is an example of a GUI that shows a dialog for inputtinginformation regarding where the personal data related to a campaign isstored.

FIG. 13 is an example of a GUI that shows information regarding theaccess of personal data related to a campaign.

FIG. 14 is an example of an instant messaging session overlaid on top ofa GUI, wherein the GUI contains prompts for the entry or selection ofcampaign data.

FIG. 15 is an example of a GUI showing an inventory page.

FIG. 16 is an example of a GUI showing campaign data, including a dataflow diagram.

FIG. 17 is an example of a GUI showing a web page that allows editing ofcampaign data.

FIGS. 18A-18B depict a flow chart showing an example of a processperformed by the Data Privacy Compliance Module.

FIGS. 19A-19B depict a flow chart showing an example of a processperformed by the Privacy Assessment Report Module.

FIG. 20 is a flow chart showing an example of a process performed by thePrivacy Assessment Monitoring Module according to particularembodiments.

FIG. 21 is a flow chart showing an example of a process performed by thePrivacy Assessment Modification Module.

FIG. 22 depicts an exemplary vendor risk scanning system according toparticular embodiments.

FIG. 23 is a flow chart showing an example of a process performed by theVendor Incident Notification Module according to particular embodiments.

FIG. 24 is a flow chart showing an example of a process performed by theVendor Compliance Demonstration Module according to particularembodiments.

FIG. 25 is a flow chart showing an example of a process performed by theVendor Information Update Module according to particular embodiments.

FIG. 26 is a flow chart showing an example of a process performed by theVendor Privacy Risk Score Calculation Module according to particularembodiments.

FIG. 27 is a flow chart showing an example of a process performed by theVendor Privacy Risk Determination Module according to particularembodiments.

FIG. 28 is a flow chart showing an example of a process performed by theDynamic Vendor Privacy Training Material Generation Module according toparticular embodiments.

FIG. 29 is a flow chart showing an example of a process performed by theDynamic Vendor Privacy Training Material Update Module according toparticular embodiments.

FIG. 30 is an example of a GUI showing a listing of vendors.

FIG. 31 is an example of a GUI showing incident details.

FIG. 32 is another example of a GUI showing incident details.

FIG. 33 is an example of a GUI showing a vendor-related task.

FIG. 34 is an example of a GUI showing a listing of vendor-relatedtasks.

FIG. 35 is another example of a GUI showing a listing of vendors.

FIG. 36 is another example of a GUI showing a listing of vendors.

FIG. 37 is an example of a GUI allowing entry of vendor information.

FIG. 38 is an example of a GUI showing a listing of vendor-relateddocuments and allowing the addition of vendor-related documents.

FIG. 39 is an example of a GUI showing details of vendor-relateddocuments.

FIG. 40 is an example of a GUI showing the analysis of vendorinformation.

FIG. 41 is an example of a GUI showing an overview of vendorinformation.

FIG. 42 is an example of a GUI showing vendor information details.

FIG. 43 is an example of a GUI for requesting a vendor assessment.

FIG. 44 is an example of a GUI indicating the detection of a vendorassessment.

FIG. 45 is an example of a GUI allowing entry of vendor assessmentinformation.

FIG. 46 is another example of a GUI allowing entry of vendor assessmentinformation.

FIG. 47 is an example of a GUI showing a listing of vendors and anindication of a change in vendor information.

FIG. 48 is another example of a GUI showing a listing of vendors.

FIG. 49 is another example of a GUI showing an overview of vendorinformation.

FIG. 50 is another example of a GUI showing vendor information details.

FIG. 51 is another example of a GUI showing a listing of vendors.

FIG. 52 is another example of a GUI showing an overview of vendorinformation.

FIG. 53 is another example of a GUI showing a listing of vendors and anindication of a change in vendor information.

FIG. 54 illustrates an exemplary data structure representing an aspectof an ontology that may be used to determine disclosure requirements forvarious territories according to various embodiments.

FIG. 55 is a flow chart showing an example of a process performed by theDisclosure Compliance Module according to particular embodiments.

FIG. 56 is an example of a GUI indicating territories that requirenotification of a data breach.

FIG. 57 is an example of a GUI indicating data breach notificationdetails for a particular territory.

FIG. 58 illustrates an exemplary data structure representing an aspectof an ontology that may be used to determine compliance with variousprivacy standards and regulations according to various embodiments.

FIG. 59 is a flow chart showing an example of a process performed by thePrivacy Standard Compliance Module according to particular embodiments.

FIG. 60 illustrates an exemplary data structure representing an aspectof an ontology that may be used to determine an entity's compliancereadiness for various and regions territories according to variousembodiments.

FIG. 61 is a flow chart showing an example of a process performed by theGlobal Readiness Assessment Module according to particular embodiments.

FIG. 62 is an example of a GUI allowing user selection of territoriesand regions for compliance readiness assessment.

FIG. 63 is an example of a GUI showing user selection of territories andregions for compliance readiness assessment.

FIG. 64 is an example of a GUI showing compliance details forregulations associated with a territory or region selected forcompliance readiness assessment.

FIG. 65 is an example of a GUI showing the results of a compliancereadiness assessment.

FIG. 66 is a flow chart showing an example of a process performed by theDisclosure Prioritization Module according to particular embodiments.

FIG. 67 is a flow chart showing an example of a process performed by theData Breach Reporting Module according to particular embodiments.

FIG. 68 is a flow chart showing an example of a process performed by theRegulatory Conflict Resolution Module according to particularembodiments.

FIG. 69 is an example of a GUI allowing user entry of data breachinformation for disclosure requirement analysis and data breachreporting.

FIG. 70 is an example of another GUI allowing user entry of data breachinformation for disclosure requirement analysis and data breachreporting.

FIG. 71 is an example of a GUI showing a heat map of jurisdictions inwhich reporting of a data breach may be required and associatedreporting tasks.

FIG. 72 is an example of a GUI showing a map of jurisdictions in whichreporting of a data breach may be required and associated reportingtasks.

FIG. 73 is an example of a GUI showing a listing of data breachreporting tasks.

FIG. 74 is an example of a GUI allowing user entry of information asresponse to questions in a master questionnaire.

DETAILED DESCRIPTION

Various embodiments now will be described more fully hereinafter withreference to the accompanying drawings. It should be understood that theinvention may be embodied in many different forms and should not beconstrued as limited to the embodiments set forth herein. Rather, theseembodiments are provided so that this disclosure will be thorough andcomplete, and will fully convey the scope of the invention to thoseskilled in the art. Like numbers refer to like elements throughout.

Overview

According to exemplary embodiments, a system for operationalizingprivacy compliance is described herein. The system may be comprised ofone or more servers and client computing devices that execute softwaremodules that facilitate various functions.

A Main Privacy Compliance Module is operable to allow a user to initiatethe creation of a privacy campaign (i.e., a business function, system,product, technology, process, project, engagement, initiative, campaign,etc., that may utilize personal data collected from one or more personsor entities). The personal data may contain PII that may be sensitivepersonal data. The user can input information such as the name anddescription of the campaign. The user may also select whether he/shewill take ownership of the campaign (i.e., be responsible for providingthe information needed to create the campaign and oversee the conductingof privacy audits related to the campaign), or assign the campaign toone or more other persons. The Main Privacy Compliance Module cangenerate a sequence or serious of GUI windows that facilitate the entryof campaign data representative of attributes related to the privacycampaign (e.g., attributes that might relate to the description of thepersonal data, what personal data is collected, whom the data iscollected from, the storage of the data, and access to that data).

Based on the information input, a Risk Assessment Module may be operableto take into account Weighting Factors and Relative Risk Ratingsassociated with the campaign in order to calculate a numerical RiskLevel associated with the campaign, as well as an Overall RiskAssessment for the campaign (i.e., low-risk, medium risk, or high risk).The Risk Level may be indicative of the likelihood of a breach involvingpersonal data related to the campaign being compromised (i.e., lost,stolen, accessed without authorization, inadvertently disclosed,maliciously disclosed, etc.). An inventory page can visually depict theRisk Level for one or more privacy campaigns.

After the Risk Assessment Module has determined a Risk Level for acampaign, a Privacy Audit Module may be operable to use the Risk Levelto determine an audit schedule for the campaign. The audit schedule maybe editable, and the Privacy Audit Module also facilitates the privacyaudit process by sending alerts when a privacy audit is impending, orsending alerts when a privacy audit is overdue.

The system may also include a Data Flow Diagram Module for generating adata flow diagram associated with a campaign. An exemplary data flowdiagram displays one or more shapes representing the source from whichdata associated with the campaign is derived, the destination (orlocation) of that data, and which departments or software systems mayhave access to the data. The Data Flow Diagram Module may also generateone or more security indicators for display. The indicators may include,for example, an “eye” icon to indicate that the data is confidential, a“lock” icon to indicate that the data, and/or a particular flow of data,is encrypted, or an “unlocked lock” icon to indicate that the data,and/or a particular flow of data, is not encrypted. Data flow lines maybe colored differently to indicate whether the data flow is encrypted orunencrypted.

The system also provides for a Communications Module that facilitatesthe creation and transmission of notifications and alerts (e.g., viaemail). The Communications Module may also instantiate an instantmessaging session and overlay the instant messaging session over one ormore portions of a GUI in which a user is presented with prompts toenter or select information.

In particularly embodiments, a vendor risk scanning system is configuredto scan one or more webpages associated with a particular vendor (e.g.,provider of particular software, particular entity, etc.) in order toidentify one or more vendor attributes. In particular embodiments, thesystem may be configured to scan the one or more web pages to identifyone or more vendor attributes such as, for example: (1) one or moresecurity certifications that the vendor does or does not have (e.g., ISO27001, SOC II Type 2, etc.); (2) one or more awards and/or recognitionsthat the vendor has received (e.g., one or more security awards); (3)one or more security policies and/or 3^(rd) party vendor parties; (4)one or more privacy policies and/or cookie policies for the one or morewebpages; (5) one or more key partners or potential sub processors ofone or more services associated with the vendor; and/or (6) any othersuitable vendor attribute. Other suitable vendor attributes may include,for example, membership in a Privacy Shield, use of StandardizedInformation Gathering (SIG), etc.

In various embodiments, the system is configured to scan the one or morewebpages by: (1) scanning one or more pieces of computer code associatedwith the one or more webpages (e.g., HTML, Java, etc.); (2) scanning oneor more contents of the one or more webpages (e.g., using one or morenatural language processing techniques); (3) scanning for one or moreparticular images on the one or more webpages (e.g., one or more imagesthat indicate membership in a particular organization, receipt of aparticular award etc.; and/or (4) using any other suitable scanningtechnique. The system may, for example, identify one or more image hostsof one or more images identified on the website, analyze the contents ofa particular identified privacy or cookie policy that is displayed onthe one or more webpages, etc. The system may, for example, beconfigured to automatically detect the one or more vendor attributesdescribed above.

In various embodiments, the system may, for example: (1) analyze the oneor more vendor attributes; and (2) calculate a risk rating for thevendor based at least in part on the one or more vendor attributes. Inparticular embodiments, the system is configured to automatically assigna suitable weighting factor to each of the one or more vendor attributeswhen calculating the risk rating. In particular embodiments, the systemis configured to analyze one or more pieces of the vendor's publishedapplications of software available to one or more customers for downloadvia the one or more webpages to detect one or more privacy disclaimersassociated with the published applications. The system may then, forexample, be configured to use one or more text matching techniques todetermine whether the one or more privacy disclaimers contain one ormore pieces of language required by one or more prevailing industry orlegal requirements related to data privacy. The system may, for example,be configured to assign a relatively low risk score to a vendor whosesoftware (e.g., and/or webpages) includes required privacy disclaimers,and configured to assign a relatively high risk score to a vendor whoseone or more webpages do not include such disclaimers.

In another example, the system may be configured to analyze one or morewebsites associated with a particular vendor for one or more privacynotices, one or more blog posts, one or more preference centers, and/orone or more control centers. The system may, for example, calculate thevendor risk score based at least in part on a presence of one or moresuitable privacy notices, one or more contents of one or more blog postson the vendor site (e.g., whether the vendor sire has one or more blogposts directed toward user privacy), a presence of one or morepreference or control centers that enable visitors to the site to opt inor out of certain data collection policies (e.g., cookie policies,etc.), etc.

In particular other embodiments, the system may be configured todetermine whether the particular vendor holds one or more securitycertifications. The one or more security certifications may include, forexample: (1) system and organization control (SOC); (2) InternationalOrganization for Standardization (ISO); (3) Health Insurance Portabilityand Accountability ACT (HIPPA); (4) etc. In various embodiments, thesystem is configured to access one or more public databases of securitycertifications to determine whether the particular vendor holds anyparticular certification. The system may then determine the privacyawareness score based on whether the vendor holds one or more securitycertifications (e.g., the system may calculate a relatively higher scoredepending on one or more particular security certifications held by thevendor). The system may be further configured to scan a vendor websitefor an indication of the one or more security certifications. The systemmay, for example, be configured to identify one or more images indicatedreceipt of the one or more security certifications, etc.

In still other embodiments, the system is configured to analyze one ormore social networking sites (e.g., Linkedln, Facebook, etc.) and/or oneor more business related job sites (e.g., one or more job-posting sites,one or more corporate websites, etc.) or other third-party websites thatare associated with the vendor (e.g., but not maintained by the vendor).The system may, for example, use social networking and other data toidentify one or more employee titles of the vendor, one or more jobroles for one or more employees of the vendor, one or more job postingsfor the vendor, etc. The system may then analyze the one or more jobtitles, postings, listings, roles, etc. to determine whether the vendorhas or is seeking one or more employees that have a role associated withdata privacy or other privacy concerns. In this way, the system maydetermine whether the vendor is particularly focused on privacy or otherrelated activities. The system may then calculate a privacy awarenessscore and/or risk rating based on such a determination (e.g., a vendorthat has one or more employees whose roles or titles are related toprivacy may receive a relatively higher privacy awareness score).

In particular embodiments, the system may be configured to calculate theprivacy awareness score using one or more additional factors such as,for example: (1) public information associated with one or more eventsthat the vendor is attending; (2) public information associated with oneor more conferences that the vendor has participated in or is planningto participate in; (3) etc. In some embodiments, the system maycalculate a privacy awareness score based at least in part on one ormore government relationships with the vendor. For example, the systemmay be configured to calculate a relatively high privacy awareness scorefor a vendor that has one or more contracts with one or more governmententities (e.g., because an existence of such a contract may indicatethat the vendor has passed one or more vetting requirements imposed bythe one or more government entities).

In any embodiment described herein, the system may be configured toassign, identify, and/or determine a weighting factor for each of aplurality of factors used to determine a risk rating score for aparticular vendor. For example, when calculating the rating, the systemmay assign a first weighting factor to whether the vendor has one ormore suitable privacy notices posted on the vendor website, a secondweighting factor to whether the vendor has one or more particularsecurity certifications, etc. The system may, for example, assign one ormore weighting factors using any suitable technique described hereinwith relation to risk rating determination. In some embodiments, thesystem may be configured to receive the one or more weighting factors(e.g., from a user). In other embodiments, the system may be configuredto determine the one or more weighting factors based at least in part ona type of the factor.

In any embodiment described herein, the system may be configured todetermine an overall risk rating for a particular vendor (e.g.,particular piece of vendor software) based in part on the privacyawareness score. In other embodiments, the system may be configured todetermine an overall risk rating for a particular vendor based on theprivacy awareness rating in combination with one or more additionalfactors (e.g., one or more additional risk factors described herein). Inany such embodiment, the system may assign one or more weighting factorsor relative risk ratings to each of the privacy awareness score andother risk factors when calculating an overall risk rating. The systemmay then be configured to provide the risk score for the vendor,software, and/or service for use in calculating a risk of undertaking aparticular processing activity that utilizes the vendor, software,and/or service (e.g., in any suitable manner described herein).

In a particular example, the system may be configured to identifywhether the vendor is part of a Privacy Shield arrangement. Inparticular, a privacy shield arrangement may facilitate monitoring of anentity's compliance with one or more commitments and enforcement ofthose commitments under the privacy shield. In particular, an entityentering a privacy shield arrangement may, for example: (1) be obligatedto publicly commit to robust protection of any personal data that ithandles; (2) be required to establish a clear set of safeguards andtransparency mechanisms on who can access the personal data it handles;and/or (3) be required to establish a redress right to addresscomplaints about improper access to the personal data.

In a particular example of a privacy shield, a privacy shield betweenthe United States and Europe may involve, for example: (1) establishmentof responsibility by the U.S. Department of Commerce to monitor anentity's compliance (e.g., a company's compliance) with its commitmentsunder the privacy shield; and (2) establishment of responsibility of theFederal Trade Commission having enforcement authority over thecommitments. In a further example, the U.S. Department of Commerce maydesignate an ombudsman to hear complaints from Europeans regarding U.S.surveillance that affects personal data of Europeans.

In some embodiments, the one or more regulations may include aregulation that allows data transfer to a country or entity thatparticipates in a safe harbor and/or privacy shield as discussed herein.The system may, for example, be configured to automatically identify atransfer that is subject to a privacy shield and/or safe harbor as ‘lowrisk.’ In this example, U.S. Privacy Shield members may be maintained ina database of privacy shield members (e.g., on one or more particularwebpages such as at www.privacyshield.gov). The system may be configuredto scan such webpages to identify whether the vendor is part of theprivacy shield.

In particular embodiments, the system may be configured to monitor theone or more websites (e.g., one or more webpages) to identify one ormore changes to the one or more vendor attributes. For example, a vendormay update a privacy policy for the website (e.g., to comply with one ormore legal or policy changes). In some embodiments, a change in aprivacy policy may modify a relationship between a website and itsusers. In such embodiments, the system may be configured to: (1)determine that a particular website has changed its privacy policy; and(2) perform a new scan of the website in response to determining thechange. The system may, for example, scan a website's privacy policy ata first time and a second time to determine whether a change hasoccurred. The system may be configured to analyze the change in privacypolicy to determine whether to modify the calculated risk rating for thevendor (e.g., based on the change).

The system may, for example, be configured to continuously monitor forone or more changes. In other embodiments, the system may be configuredto scan for one or more changes according to a particular schedule(e.g., hourly, daily, weekly, or any other suitable schedule.). Forexample, the system may be configured to scan the one or more webpageson an ongoing basis to determine whether the one or more vendorattributes have changed (e.g., if the vendor did not renew its PrivacyShield membership, lost its ISO certification, etc.).

Technical Contributions of Various Embodiments

An entity that handles (e.g., collects, receives, transmits, stores,processes, shares, and/or the like) sensitive and/or personalinformation associated with particular individuals (e.g., personallyidentifiable information (PII) data, sensitive data, personal data,etc.) may be subject to various laws, regulations, and/or requirementsregarding the handling of such personal data. As part of such laws,regulations, and/or requirements, an entity may be required to complywith one or more requirements related to a breach of such information(e.g., as a result of a data breach). Because the applicable laws,regulations, and/or requirements may vary based on the jurisdiction ofthe entity, the jurisdiction of a user (“data subject”), the products orservices involved, and/or the jurisdiction in which user data ishandled, the applicable data breach response requirements may differfrom situation to situation, conflict with one another, or includerequirements that are not possible to fully comply with. Due to the vastnumber of possible situations in which different data breachrequirements may apply and the varying requirements of each, there maybe large numbers of potentially applicable data breach responserequirements for any one particular situation. Therefore, an entity mayneed to ensure that it reconciles data breach response requirements sothat the entity minimize risks related to complying with applicablelaws, regulations, and/or requirements related to a data breach.

Accordingly, various embodiments of present disclosure overcome many ofthe technical challenges associated with configuring and generating agraphical user interface that presents the data breach responserequirements based on a response plan by evaluating data breach responserequirements against prioritization data. Specifically, variousembodiments of the disclosure are directed to a computational frameworkconfigured for using data breach response prioritization data todetermine the appropriate navigational elements to present to the userin a graphical user interface in order to display different data breachresponse requirements. The system may identify one or more navigationalelements that correspond to the determined one or more privacy policydatasets to configure on a graphical user interface. The system mayalso, or instead, identify one or more navigational elements that do notcorrespond to particular data breach response requirements and may, inresponse, determine to exclude those one or more navigational elementsfrom a graphical user interface presented to the user. Thesenavigational elements included in the graphical user interface, whenactivated, may cause the user device to retrieve and present thecorresponding data breach requirements to the user.

In various embodiments described herein, the system (e.g., a rulesengine executed by the system) may use parameters to identify andreconcile particular data breach response requirements for a particularsituation. The system can then evaluate the response requirementsagainst prioritization data in order to determine which responserequirements to include as part of a response plan. Once the responseplan is generated, the system may determine the appropriate navigationalelement to configure on a graphical user interface that, when activatedby a user, causes the user device to retrieve and presents the responserequirement associated with that navigational element.

Accordingly, various embodiments of the disclosure provided herein aremore effective, efficient, timely, accurate, and faster in determiningthe appropriate graphical user interface elements for presentation on agraphical user interface to a user to in a specific situation so thatthe user may obtain data breach response requirements. In addition,various embodiments provided herein may facilitate the identification ofappropriate graphical user interface elements by using the data breachresponse prioritization data described herein. By properly identifyingthe most applicable graphical user interface elements for a specificsituation, the various embodiments help ensure that a user can beprovided with an optimized response plan that includes particularresponse requirements when addressing a data breach. This is especiallyadvantageous when a data breach affects users in multiple jurisdictions.In facilitating the identification of the applicable graphical userinterface elements in many various types of situations, the variousembodiments of the present disclosure make major technical contributionsto improving the computational efficiency and reliability of variousprivacy management systems and procedures for determining and providinggraphical user interface elements that correspond to data breachresponse requirements identified based on prioritization data. This inturn translates to more computationally efficient software systems.Further detail is now provided for different aspects of variousembodiments of the disclosure.

Exemplary Technical Platforms

As will be appreciated by one skilled in the relevant field, a systemfor operationalizing privacy compliance and assessing risk of privacycampaigns may be, for example, embodied as a computer system, a method,or a computer program product. Accordingly, various embodiments may takethe form of an entirely hardware embodiment, an entirely softwareembodiment, or an embodiment combining software and hardware aspects.Furthermore, particular embodiments may take the form of a computerprogram product stored on a computer-readable storage medium havingcomputer-readable instructions (e.g., software) embodied in the storagemedium. Various embodiments may take the form of web, mobile, wearablecomputer-implemented, computer software. Any suitable computer-readablestorage medium may be utilized including, for example, hard disks,compact disks, DVDs, optical storage devices, and/or magnetic storagedevices.

Various embodiments are described below with reference to block diagramsand flowchart illustrations of methods, apparatuses (e.g., systems) andcomputer program products. It should be understood that each step of theblock diagrams and flowchart illustrations, and combinations of steps inthe block diagrams and flowchart illustrations, respectively, may beimplemented by a computer executing computer program instructions. Thesecomputer program instructions may be loaded onto a general purposecomputer, special purpose computer, or other programmable dataprocessing apparatus to produce a machine, such that the instructionswhich execute on the computer or other programmable data processingapparatus to create means for implementing the functions specified inthe flowchart step or steps

These computer program instructions may also be stored in acomputer-readable memory that may direct a computer or otherprogrammable data processing apparatus to function in a particularmanner such that the instructions stored in the computer-readable memoryproduce an article of manufacture that is configured for implementingthe function specified in the flowchart step or steps. The computerprogram instructions may also be loaded onto a computer or otherprogrammable data processing apparatus to cause a series of operationalsteps to be performed on the computer or other programmable apparatus toproduce a computer implemented process such that the instructions thatexecute on the computer or other programmable apparatus provide stepsfor implementing the functions specified in the flowchart step or steps.

Accordingly, steps of the block diagrams and flowchart illustrationssupport combinations of mechanisms for performing the specifiedfunctions, combinations of steps for performing the specified functions,and program instructions for performing the specified functions. Itshould also be understood that each step of the block diagrams andflowchart illustrations, and combinations of steps in the block diagramsand flowchart illustrations, may be implemented by special purposehardware -based computer systems that perform the specified functions orsteps, or combinations of special purpose hardware and other hardwareexecuting appropriate computer instructions.

Example System Architecture

FIG. 1 is a block diagram of a System 100 according to a particularembodiment. As may be understood from this figure, the System 100includes one or more computer networks 110, a Server 120, a StorageDevice 130 (which may contain one or more databases of information), oneor more remote client computing devices such as a tablet computer 140, adesktop or laptop computer 150, or a handheld computing device 160, suchas a cellular phone, browser and Internet capable set-top boxes 170connected with a TV 180, or even smart TVs 180 having browser andInternet capability. The client computing devices attached to thenetwork may also include copiers/printers 190 having hard drives (asecurity risk since copies/prints may be stored on these hard drives).The Server 120, client computing devices, and Storage Device 130 may bephysically located in a central location, such as the headquarters ofthe organization, for example, or in separate facilities. The devicesmay be owned or maintained by employees, contractors, or other thirdparties (e.g., a cloud service provider). In particular embodiments, theone or more computer networks 115 facilitate communication between theServer 120, one or more client computing devices 140, 150, 160, 170,180, 190, and Storage Device 130.

The one or more computer networks 115 may include any of a variety oftypes of wired or wireless computer networks such as the Internet, aprivate intranet, a public switched telephone network (PSTN), or anyother type of network. The communication link between the Server 120,one or more client computing devices 140, 150, 160, 170, 180, 190, andStorage Device 130 may be, for example, implemented via a Local AreaNetwork (LAN) or via the Internet.

Example Computer Architecture Used Within the System

FIG. 2 illustrates a diagrammatic representation of the architecture ofa computer 200 that may be used within the System 100, for example, as aclient computer (e.g., one of computing devices 140, 150, 160, 170, 180,190, shown in FIG. 1), or as a server computer (e.g., Server 120 shownin FIG. 1). In exemplary embodiments, the computer 200 may be suitablefor use as a computer within the context of the System 100 that isconfigured to operationalize privacy compliance and assess risk ofprivacy campaigns. In particular embodiments, the computer 200 may beconnected (e.g., networked) to other computers in a LAN, an intranet, anextranet, and/or the Internet. As noted above, the computer 200 mayoperate in the capacity of a server or a client computer in aclient-server network environment, or as a peer computer in apeer-to-peer (or distributed) network environment. The computer 200 maybe a personal computer (PC), a tablet PC, a set-top box (STB), aPersonal Digital Assistant (PDA), a cellular telephone, a web appliance,a server, a network router, a switch or bridge, or any other computercapable of executing a set of instructions (sequential or otherwise)that specify actions to be taken by that computer. Further, while only asingle computer is illustrated, the term “computer” shall also be takento include any collection of computers that individually or jointlyexecute a set (or multiple sets) of instructions to perform any one ormore of the methodologies discussed herein.

An exemplary computer 200 includes a processing device 202, a mainmemory 204 (e.g., read-only memory (ROM), flash memory, dynamic randomaccess memory (DRAM) such as synchronous DRAM (SDRAM) or Rambus DRAM(RDRAM), etc.), a static memory 206 (e.g., flash memory, static randomaccess memory (SRAM), etc.), and a data storage device 218, whichcommunicate with each other via a bus 232.

The processing device 202 represents one or more general-purposeprocessing devices such as a microprocessor, a central processing unit,or the like. More particularly, the processing device 202 may be acomplex instruction set computing (CISC) microprocessor, reducedinstruction set computing (RISC) microprocessor, very long instructionword (VLIW) microprocessor, or processor implementing other instructionsets, or processors implementing a combination of instruction sets. Theprocessing device 202 may also be one or more special-purpose processingdevices such as an application specific integrated circuit (ASIC), afield programmable gate array (FPGA), a digital signal processor (DSP),network processor, or the like. The processing device 202 may beconfigured to execute processing logic 226 for performing variousoperations and steps discussed herein.

The computer 200 may further include a network interface device 208. Thecomputer 200 also may include a video display unit 210 (e.g., a liquidcrystal display (LCD) or a cathode ray tube (CRT)), an alphanumericinput device 212 (e.g., a keyboard), a cursor control device 214 (e.g.,a mouse), and a signal generation device 216 (e.g., a speaker). The datastorage device 218 may include a non-transitory computer-readablestorage medium 230 (also known as a non-transitory computer-readablestorage medium or a non-transitory computer-readable medium) on which isstored one or more sets of instructions 222 (e.g., software, softwaremodules) embodying any one or more of the methodologies or functionsdescribed herein. The software 222 may also reside, completely or atleast partially, within main memory 204 and/or within processing device202 during execution thereof by computer 200—main memory 204 andprocessing device 202 also constituting computer-accessible storagemedia. The software 222 may further be transmitted or received over anetwork 115 via network interface device 208.

While the computer-readable storage medium 230 is shown in an exemplaryembodiment to be a single medium, the terms “computer-readable storagemedium” and “machine-accessible storage medium” should be understood toinclude a single medium or multiple media (e.g., a centralized ordistributed database, and/or associated caches and servers) that storethe one or more sets of instructions. The term “computer-readablestorage medium” should also be understood to include any medium that iscapable of storing, encoding or carrying a set of instructions forexecution by the computer and that cause the computer to perform any oneor more of the methodologies of the present invention. The term“computer-readable storage medium” should accordingly be understood toinclude, but not be limited to, solid-state memories, optical andmagnetic media, etc.

Exemplary System Platform

According to various embodiments, the processes and logic flowsdescribed in this specification may be performed by a system (e.g.,System 100) that includes, but is not limited to, one or moreprogrammable processors (e.g., processor 202) executing one or morecomputer program modules to perform functions by operating on input dataand generating output, thereby tying the process to a particular machine(e.g., a machine programmed to perform the processes described herein).This includes processors located in one or more of client computers(e.g., client computers 140, 150, 160, 170, 180, 190 of FIG. 1). Thesedevices connected to network 110 may access and execute one or moreInternet browser-based program modules that are “served up” through thenetwork 110 by one or more servers (e.g., server 120 of FIG. 1), and thedata associated with the program may be stored on a one or more storagedevices, which may reside within a server or computing device (e.g.,Main Memory 204, Static Memory 206), be attached as a peripheral storagedevice to the one or more servers or computing devices, or attached tothe network (e.g., Storage 130).

The System 100 facilitates the acquisition, storage, maintenance, use,and retention of campaign data associated with a plurality of privacycampaigns within an organization. In doing so, various aspects of theSystem 100 initiates and creates a plurality of individual data privacycampaign records that are associated with a variety of privacy-relatedattributes and assessment related meta-data for each campaign. Thesedata elements may include: the subjects of the sensitive information,the respective person or entity responsible for each campaign (e.g., thecampaign's “owner”), the location where the personal data will bestored, the entity or entities that will access the data, the parametersaccording to which the personal data will be used and retained, the RiskLevel associated with a particular campaign (as well as assessments fromwhich the Risk Level is calculated), an audit schedule, and otherattributes and meta-data. The System 100 may also be adapted tofacilitate the setup and auditing of each privacy campaign. Thesemodules may include, for example, a Main Privacy Compliance Module, aRisk Assessment Module, a Privacy Audit Module, a Data Flow DiagramModule, a Communications Module (examples of which are described below),a Privacy Assessment Monitoring Module, and a Privacy AssessmentModification Module. It is to be understood that these are examples ofmodules of various embodiments, but the functionalities performed byeach module as described may be performed by more (or less) modules.Further, the functionalities described as being performed by one modulemay be performed by one or more other modules.

A. Example Elements Related to Privacy Campaigns

FIG. 3 provides a high-level visual overview of example “subjects” forparticular data privacy campaigns, exemplary campaign “owners,” variouselements related to the storage and access of personal data, andelements related to the use and retention of the personal data. Each ofthese elements may, in various embodiments, be accounted for by theSystem 100 as it facilitates the implementation of an organization'sprivacy compliance policy.

As may be understood from FIG. 3, sensitive information may be collectedby an organization from one or more subjects 300. Subjects may includecustomers whose information has been obtained by the organization. Forexample, if the organization is selling goods to a customer, theorganization may have been provided with a customer's credit card orbanking information (e.g., account number, bank routing number), socialsecurity number, or other sensitive information.

An organization may also possess personal data originating from one ormore of its business partners. Examples of business partners are vendorsthat may be data controllers or data processors (which have differentlegal obligations under EU data protection laws). Vendors may supply acomponent or raw material to the organization, or an outside contractorresponsible for the marketing or legal work of the organization. Thepersonal data acquired from the partner may be that of the partners, oreven that of other entities collected by the partners. For example, amarketing agency may collect personal data on behalf of theorganization, and transfer that information to the organization.Moreover, the organization may share personal data with one of itspartners. For example, the organization may provide a marketing agencywith the personal data of its customers so that it may conduct furtherresearch.

Other subjects 300 include the organization's own employees.Organizations with employees often collect personal data from theiremployees, including address and social security information, usuallyfor payroll purposes, or even prior to employment, for conducting creditchecks. The subjects 300 may also include minors. It is noted thatvarious corporate privacy policies or privacy laws may require thatorganizations take additional steps to protect the sensitive privacy ofminors.

Still referring to FIG. 3, within an organization, a particularindividual (or groups of individuals) may be designated to be an “owner”of a particular campaign to obtain and manage personal data. Theseowners 310 may have any suitable role within the organization. Invarious embodiments, an owner of a particular campaign will have primaryresponsibility for the campaign, and will serve as a resident expertregarding the personal data obtained through the campaign, and the waythat the data is obtained, stored, and accessed. As shown in FIG. 3, anowner may be a member of any suitable department, including theorganization's marketing, HR, R&D, or IT department. As will bedescribed below, in exemplary embodiments, the owner can always bechanged, and owners can sub-assign other owners (and othercollaborators) to individual sections of campaign data input andoperations.

Referring still to FIG. 3, the system may be configured to account forthe use and retention 315 of personal data obtained in each particularcampaign. The use and retention of personal data may include how thedata is analyzed and used within the organization's operations, whetherthe data is backed up, and which parties within the organization aresupporting the campaign.

The system may also be configured to help manage the storage and access320 of personal data. As shown in FIG. 3, a variety of different partiesmay access the data, and the data may be stored in any of a variety ofdifferent locations, including on-site, or in “the cloud”, i.e., onremote servers that are accessed via the Internet or other suitablenetwork.

B. Main Compliance Module

FIG. 4 illustrates an exemplary process for operationalizing privacycompliance. Main Privacy Compliance Module 400, which may be executed byone or more computing devices of System 100, may perform this process.In exemplary embodiments, a server (e.g., server 140) in conjunctionwith a client computing device having a browser, execute the MainPrivacy Compliance Module (e.g., computing devices 140, 150, 160, 170,180, 190) through a network (network 110). In various exemplaryembodiments, the Main Privacy Compliance Module 400 may call upon othermodules to perform certain functions. In exemplary embodiments, thesoftware may also be organized as a single module to perform variouscomputer executable routines.

I. Adding a Campaign

The process 400 may begin at step 405, wherein the Main PrivacyCompliance Module 400 of the System 100 receives a command to add aprivacy campaign. In exemplary embodiments, the user selects anon-screen button (e.g., the Add Data Flow button 1555 of FIG. 15) thatthe Main Privacy Compliance Module 400 displays on a landing page, whichmay be displayed in a graphical user interface (GUI), such as a window,dialog box, or the like. The landing page may be, for example, theinventory page 1500 below. The inventory page 1500 may display a list ofone or more privacy campaigns that have already been input into theSystem 100. As mentioned above, a privacy campaign may represent, forexample, a business operation that the organization is engaged in, orsome business record, that may require the use of personal data, whichmay include the personal data of a customer or some other entity.Examples of campaigns might include, for example, Internet UsageHistory, Customer Payment Information, Call History Log, CellularRoaming Records, etc. For the campaign “Internet Usage History,” amarketing department may need customers' on-line browsing patterns torun analytics. This might entail retrieving and storing customers' IPaddresses, MAC address, URL history, subscriber ID, and otherinformation that may be considered personal data (and even sensitivepersonal data). As will be described herein, the System 100, through theuse of one or more modules, including the Main Privacy Campaign Module400, creates a record for each campaign. Data elements of campaign datamay be associated with each campaign record that represents attributessuch as: the type of personal data associated with the campaign; thesubjects having access to the personal data; the person or personswithin the company that take ownership (e.g., business owner) forensuring privacy compliance for the personal data associated with eachcampaign; the location of the personal data; the entities having accessto the data; the various computer systems and software applications thatuse the personal data; and the Risk Level (see below) associated withthe campaign.

II. Entry of Privacy Campaign Related Information, Including Owner

At step 410, in response to the receipt of the user's command to add aprivacy campaign record, the Main Privacy Compliance Module 400initiates a routine to create an electronic record for a privacycampaign, and a routine for the entry data inputs of information relatedto the privacy campaign. The Main Privacy Compliance Module 400 maygenerate one or more graphical user interfaces (e.g., windows, dialogpages, etc.), which may be presented one GUI at a time. Each GUI mayshow prompts, editable entry fields, check boxes, radial selectors,etc., where a user may enter or select privacy campaign data. Inexemplary embodiments, the Main Privacy Compliance Module 400 displayson the graphical user interface a prompt to create an electronic recordfor the privacy campaign. A user may choose to add a campaign, in whichcase the Main Privacy Compliance Module 400 receives a command to createthe electronic record for the privacy campaign, and in response to thecommand, creates a record for the campaign and digitally stores therecord for the campaign. The record for the campaign may be stored in,for example, storage 130, or a storage device associated with the MainPrivacy Compliance Module (e.g., a hard drive residing on Server 110, ora peripheral hard drive attached to Server 110).

The user may be a person who works in the Chief Privacy Officer'sorganization (e.g., a privacy office rep, or privacy officer). Theprivacy officer may be the user that creates the campaign record, andenters initial portions of campaign data (e.g., “high level” datarelated to the campaign), for example, a name for the privacy campaign,a description of the campaign, and a business group responsible foradministering the privacy operations related to that campaign (forexample, though the GUI shown in FIG. 6). The Main Privacy ComplianceModule 400 may also prompt the user to enter a person or entityresponsible for each campaign (e.g., the campaign's “owner”). The ownermay be tasked with the responsibility for ensuring or attempting toensure that the privacy policies or privacy laws associated withpersonal data related to a particular privacy campaign are beingcomplied with. In exemplary embodiments, the default owner of thecampaign may be the person who initiated the creation of the privacycampaign. That owner may be a person who works in the Chief PrivacyOfficer's organization (e.g., a privacy office rep, or privacy officer).The initial owner of the campaign may designate someone else to be theowner of the campaign. The designee may be, for example, arepresentative of some business unit within the organization (a businessrep). Additionally, more than one owner may be assigned. For example,the user may assign a primary business rep, and may also assign aprivacy office rep as owners of the campaign.

In many instances, some or most of the required information related tothe privacy campaign record might not be within the knowledge of thedefault owner (i.e., the privacy office rep). The Main Data ComplianceModule 400 can be operable to allow the creator of the campaign record(e.g., a privacy officer rep) to designate one or more othercollaborators to provide at least one of the data inputs for thecampaign data. Different collaborators, which may include the one ormore owners, may be assigned to different questions, or to specificquestions within the context of the privacy campaign. Additionally,different collaborators may be designated to respond to pats ofquestions. Thus, portions of campaign data may be assigned to differentindividuals.

Still referring to FIG. 4, if at step 415 the Main Privacy ComplianceModule 400 has received an input from a user to designate a new ownerfor the privacy campaign that was created, then at step 420, the MainPrivacy Compliance Module 400 may notify that individual via a suitablenotification that the privacy campaign has been assigned to him or her.Prior to notification, the Main Privacy Compliance Module 400 maydisplay a field that allows the creator of the campaign to add apersonalized message to the newly assigned owner of the campaign to beincluded with that notification. In exemplary embodiments, thenotification may be in the form of an email message. The email mayinclude the personalized message from the assignor, a standard messagethat the campaign has been assigned to him/her, the deadline forcompleting the campaign entry, and instructions to log in to the systemto complete the privacy campaign entry (along with a hyperlink thattakes the user to a GUI providing access to the Main Privacy ComplianceModule 400. Also included may be an option to reply to the email if anassigned owner has any questions, or a button that when clicked on,opens up a chat window (i.e., instant messenger window) to allow thenewly assigned owner and the assignor a GUI in which they are able tocommunicate in real-time. An example of such a notification appears inFIG. 16 below. In addition to owners, collaborators that are assigned toinput portions of campaign data may also be notified through similarprocesses. In exemplary embodiments, The Main Privacy Compliance Module400 may, for example through a Communications Module, be operable tosend collaborators emails regarding their assignment of one or moreportions of inputs to campaign data. Or through the CommunicationsModule, selecting the commentators button brings up one or morecollaborators that are on-line (with the off-line users still able tosee the messages when they are back on-line. Alerts indicate that one ormore emails or instant messages await a collaborator.

At step 425, regardless of whether the owner is the user (i.e., thecreator of the campaign), “someone else” assigned by the user, or othercollaborators that may be designated with the task of providing one ormore items of campaign data, the Main Privacy Campaign Module 400 may beoperable to electronically receive campaign data inputs from one or moreusers related to the personal data related to a privacy campaign througha series of displayed computer-generated graphical user interfacesdisplaying a plurality of prompts for the data inputs. In exemplaryembodiments, through a step-by-step process, the Main Privacy CampaignModule may receive from one or more users' data inputs that includecampaign data like: (1) a description of the campaign; (2) one or moretypes of personal data to be collected and stored as part of thecampaign; (3) individuals from which the personal data is to becollected; (4) the storage location of the personal data, and (5)information regarding who will have access to the personal data. Theseinputs may be obtained, for example, through the graphical userinterfaces shown in FIGS. 8 through 13, wherein the Main ComplianceModule 400 presents on sequentially appearing GUIs the prompts for theentry of each of the enumerated campaign data above. The Main ComplianceModule 400 may process the campaign data by electronically associatingthe campaign data with the record for the campaign and digitally storingthe campaign data with the record for the campaign. The campaign datamay be digitally stored as data elements in a database residing in amemory location in the server 120, a peripheral storage device attachedto the server, or one or more storage devices connected to the network(e.g., storage 130). If campaign data inputs have been assigned to oneor more collaborators, but those collaborators have not input the datayet, the Main Compliance Module 400 may, for example through theCommunications Module, sent an electronic message (such as an email)alerting the collaborators and owners that they have not yet suppliedtheir designated portion of campaign data.

III. Privacy Campaign Information Display

At step 430, Main Privacy Compliance Module 400 may, in exemplaryembodiments, call upon a Risk Assessment Module 430 that may determineand assign a Risk Level for the privacy campaign, based wholly or inpart on the information that the owner(s) have input. The RiskAssessment Module 430 will be discussed in more detail below.

At step 432, Main Privacy Compliance Module 400 may in exemplaryembodiments, call upon a Privacy Audit Module 432 that may determine anaudit schedule for each privacy campaign, based, for example, wholly orin part on the campaign data that the owner(s) have input, the RiskLevel assigned to a campaign, and/or any other suitable factors. ThePrivacy Audit Module 432 may also be operable to display the status ofan audit for each privacy campaign. The Privacy Audit Module 432 will bediscussed in more detail below.

At step 435, the Main Privacy Compliance Module 400 may generate anddisplay a GUI showing an inventory page (e.g., inventory page 1500) thatincludes information associated with each campaign. That information mayinclude information input by a user (e.g., one or more owners), orinformation calculated by the Main Privacy Compliance Module 400 orother modules. Such information may include for example, the name of thecampaign, the status of the campaign, the source of the campaign, thestorage location of the personal data related to the campaign, etc. Theinventory page 1500 may also display an indicator representing the RiskLevel (as mentioned, determined for each campaign by the Risk AssessmentModule 430), and audit information related to the campaign that wasdetermined by the Privacy Audit Module (see below). The inventory page1500 may be the landing page displayed to users that access the system.Based on the login information received from the user, the Main PrivacyCompliance Module may determine which campaigns and campaign data theuser is authorized to view, and display only the information that theuser is authorized to view. Also from the inventory page 1500, a usermay add a campaign (discussed above in step 405), view more informationfor a campaign, or edit information related to a campaign (see, e.g.,FIGS. 15, 16, 17).

If other commands from the inventory page are received (e.g., add acampaign, view more information, edit information related to thecampaign), then step 440, 445, and/or 450 may be executed.

At step 440, if a command to view more information has been received ordetected, then at step 445, the Main Privacy Compliance Module 400 maypresent more information about the campaign, for example, on a suitablecampaign information page 1500. At this step, the Main PrivacyCompliance Module 400 may invoke a Data Flow Diagram Module (describedin more detail below). The Data Flow Diagram Module may generate a flowdiagram that shows, for example, visual indicators indicating whetherdata is confidential and/or encrypted (see, e.g., FIG. 1600 below).

At step 450, if the system has received a request to edit a campaign,then, at step 455, the system may display a dialog page that allows auser to edit information regarding the campaign (e.g., edit campaigndialog 1700).

At step 460, if the system has received a request to add a campaign, theprocess may proceed back to step 405.

C. Risk Assessment Module

FIG. 5 illustrates an exemplary process for determining a Risk Level andOverall Risk Assessment for a particular privacy campaign performed byRisk Assessment Module 430.

I. Determining Risk Level

In exemplary embodiments, the Risk Assessment Module 430 may be operableto calculate a Risk Level for a campaign based on the campaign datarelated to the personal data associated with the campaign. The RiskAssessment Module may associate the Risk Level with the record for thecampaign and digitally store the Risk Level with the record for thecampaign.

The Risk Assessment Module 430 may calculate this Risk Level based onany of various factors associated with the campaign. The Risk AssessmentModule 430 may determine a plurality of weighting factors based upon,for example: (1) the nature of the sensitive information collected aspart of the campaign (e.g., campaigns in which medical information,financial information or non-public personal identifying information iscollected may be indicated to be of higher risk than those in which onlypublic information is collected, and thus may be assigned a highernumerical weighting factor); (2) the location in which the informationis stored (e.g., campaigns in which data is stored in the cloud may bedeemed higher risk than campaigns in which the information is storedlocally); (3) the number of individuals who have access to theinformation (e.g., campaigns that permit relatively large numbers ofindividuals to access the personal data may be deemed more risky thanthose that allow only small numbers of individuals to access the data);(4) the length of time that the data will be stored within the system(e.g., campaigns that plan to store and use the personal data over along period of time may be deemed more risky than those that may onlyhold and use the personal data for a short period of time); (5) theindividuals whose sensitive information will be stored (e.g., campaignsthat involve storing and using information of minors may be deemed ofgreater risk than campaigns that involve storing and using theinformation of adults); (6) the country of residence of the individualswhose sensitive information will be stored (e.g., campaigns that involvecollecting data from individuals that live in countries that haverelatively strict privacy laws may be deemed more risky than those thatinvolve collecting data from individuals that live in countries thathave relative lax privacy laws). It should be understood that any othersuitable factors may be used to assess the Risk Level of a particularcampaign, including any new inputs that may need to be added to the riskcalculation.

In particular embodiments, one or more of the individual factors may beweighted (e.g., numerically weighted) according to the deemed relativeimportance of the factor relative to other factors (i.e., Relative RiskRating).

These weightings may be customized from organization to organization,and/or according to different applicable laws. In particularembodiments, the nature of the sensitive information will be weightedhigher than the storage location of the data, or the length of time thatthe data will be stored.

In various embodiments, the system uses a numerical formula to calculatethe Risk Level of a particular campaign. This formula may be, forexample: Risk Level for campaign=(Weighting Factor of Factor1)*(Relative Risk Rating of Factor 1)+(Weighting Factor of Factor2)*(Relative Risk Rating of Factor 2)+ . . . (Weighting Factor of FactorN)*(Relative Risk Rating of Factor N). As a simple example, the RiskLevel for a campaign that only collects publicly available informationfor adults and that stores the information locally for a short period ofseveral weeks might be determined as Risk Level=(Weighting Factor ofNature of Sensitive Information)*(Relative Risk Rating of ParticularSensitive Information to be Collected)+(Weighting Factor of Individualsfrom which Information is to be Collected)*(Relative Risk Rating ofIndividuals from which Information is to be Collected)+(Weighting Factorof Duration of Data Retention)*(Relative Risk Rating of Duration of DataRetention)+(Weighting Factor of Individuals from which Data is to beCollected)*(Relative Risk Rating of Individuals from which Data is to beCollected). In this example, the Weighting Factors may range, forexample from 1-5, and the various Relative Risk Ratings of a factor mayrange from 1-10. However, the system may use any other suitable ranges.

In particular embodiments, the Risk Assessment Module 430 may havedefault settings for assigning Overall Risk Assessments to respectivecampaigns based on the numerical Risk Level value determined for thecampaign, for example, as described above. The organization may alsomodify these settings in the Risk Assessment Module 430 by assigning itsown Overall Risk Assessments based on the numerical Risk Level. Forexample, the Risk Assessment Module 430 may, based on default or userassigned settings, designate: (1) campaigns with a Risk Level of 1-7 as“low risk” campaigns, (2) campaigns with a Risk Level of 8-15 as “mediumrisk” campaigns; (3) campaigns with a Risk Level of over 16 as “highrisk” campaigns. As show below, in an example inventory page 1500, theOverall Risk Assessment for each campaign can be indicated by up/downarrow indicators, and further, the arrows may have different shading (orcolor, or portions shaded) based upon this Overall Risk Assessment. Theselected colors may be conducive for viewing by those who suffer fromcolor blindness.

Thus, the Risk Assessment Module 430 may be configured to automaticallycalculate the numerical Risk Level for each campaign within the system,and then use the numerical Risk Level to assign an appropriate OverallRisk Assessment to the respective campaign. For example, a campaign witha Risk Level of 5 may be labeled with an Overall Risk Assessment as “LowRisk”. The system may associate both the Risk Level and the Overall RiskAssessment with the campaign and digitally store them as part of thecampaign record.

II. Exemplary Process for Assessing Risk

Accordingly, as shown in FIG. 5, in exemplary embodiments, the RiskAssessment Module 430 electronically retrieves from a database (e.g.,storage device 130) the campaign data associated with the record for theprivacy campaign. It may retrieve this information serially, or inparallel. At step 505, the Risk Assessment Module 430 retrievesinformation regarding (1) the nature of the sensitive informationcollected as part of the campaign. At step 510, the Risk AssessmentModule 430 retrieves information regarding the (2) the location in whichthe information related to the privacy campaign is stored. At step 515,the Risk Assessment Module 430 retrieves information regarding (3) thenumber of individuals who have access to the information. At step 520,the Risk Assessment Module retrieves information regarding (4) thelength of time that the data associated with a campaign will be storedwithin the System 100. At step 525, the Risk Assessment Module retrievesinformation regarding (5) the individuals whose sensitive informationwill be stored. At step 530, the Risk Assessment Module retrievesinformation regarding (6) the country of residence of the individualswhose sensitive information will be stored.

At step 535, the Risk Assessment Module takes into account any usercustomizations to the weighting factors related to each of the retrievedfactors from steps 505, 510, 515, 520, 525, and 530. At steps 540 and545, the Risk Assessment Module applies either default settings to theweighting factors (which may be based on privacy laws), orcustomizations to the weighting factors. At step 550, the RiskAssessment Module determines a plurality of weighting factors for thecampaign. For example, for the factor related to the nature of thesensitive information collected as part of the campaign, a weightingfactor of 1-5 may be assigned based on whether non-public personalidentifying information is collected.

At step 555, the Risk Assessment Module takes into account any usercustomizations to the Relative Risk assigned to each factor, and at step560 and 565, will either apply default values (which can be based onprivacy laws) or the customized values for the Relative Risk. At step570, the Risk Assessment Module assigns a relative risk rating for eachof the plurality of weighting factors. For example, the relative riskrating for the location of the information of the campaign may beassigned a numerical number (e.g., from 1-10) that is lower than thenumerical number assigned to the Relative Risk Rating for the length oftime that the sensitive information for that campaign is retained.

At step 575, the Risk Assessment Module 430 calculates the relative riskassigned to the campaign based upon the plurality of Weighting Factorsand the Relative Risk Rating for each of the plurality of factors. As anexample, the Risk Assessment Module 430 may make this calculation usingthe formula of Risk Level=(Weighting Factor of Factor 1)*(Relative RiskRating of Factor 1)+(Weighting Factor of Factor 2)*(Relative Risk Ratingof Factor 2)+ . . . (Weighting Factor of Factor N)*(Relative Risk Ratingof Factor N).

At step 580, based upon the numerical value derived from step 575, theRisk Assessment

Module 430 may determine an Overall Risk Assessment for the campaign.The Overall Risk Assessment determination may be made for the privacycampaign may be assigned based on the following criteria, which may beeither a default or customized setting: (1) campaigns with a Risk Levelof 1-7 as “low risk” campaigns, (2) campaigns with a Risk Level of 8-15as “medium risk” campaigns; (3) campaigns with a Risk Level of over 16as “high risk” campaigns. The Overall Risk Assessment is then associatedand stored with the campaign record.

D. Privacy Audit Module

The System 100 may determine an audit schedule for each campaign, andindicate, in a particular graphical user interface (e.g., inventory page1500), whether a privacy audit is coming due (or is past due) for eachparticular campaign and, if so, when the audit is/was due. The System100 may also be operable to provide an audit status for each campaign,and alert personnel of upcoming or past due privacy audits. To furtherthe retention of evidence of compliance, the System 100 may also receiveand store evidence of compliance. A Privacy Audit Module 432, mayfacilitate these functions.

I. Determining a Privacy Audit Schedule and Monitoring Compliance

In exemplary embodiments, the Privacy Audit Module 432 is adapted toautomatically schedule audits and manage compliance with the auditschedule. In particular embodiments, the system may allow a user tomanually specify an audit schedule for each respective campaign. ThePrivacy Audit Module 432 may also automatically determine, and save tomemory, an appropriate audit schedule for each respective campaign,which in some circumstances, may be editable by the user.

The Privacy Audit Module 432 may automatically determine the auditschedule based on the determined Risk Level of the campaign. Forexample, all campaigns with a Risk Level less than 10 may have a firstaudit schedule and all campaigns with a Risk Level of 10 or more mayhave a second audit schedule. The Privacy Audit Module may also beoperable determine the audit schedule based on the Overall RiskAssessment for the campaign (e.g., “low risk” campaigns may have a firstpredetermined audit schedule, “medium risk” campaigns may have a secondpredetermined audit schedule, “high risk” campaigns may have a thirdpredetermined audit schedule, etc.).

In particular embodiments, the Privacy Audit Module 432 mayautomatically facilitate and monitor compliance with the determinedaudit schedules for each respective campaign. For example, the systemmay automatically generate one or more reminder emails to the respectiveowners of campaigns as the due date approaches. The system may also beadapted to allow owners of campaigns, or other users, to submit evidenceof completion of an audit (e.g., by for example, submitting screen shotsthat demonstrate that the specified parameters of each campaign arebeing followed). In particular embodiments, the system is configuredfor, in response to receiving sufficient electronic informationdocumenting completion of an audit, resetting the audit schedule (e.g.,scheduling the next audit for the campaign according to a determinedaudit schedule, as determined above).

II. Exemplary Privacy Audit Process

FIG. 6 illustrates an exemplary process performed by a Privacy AuditModule 432 for assigning a privacy audit schedule and facilitating andmanaging compliance for a particular privacy campaign. At step 605, thePrivacy Audit Module 432 retrieves the Risk Level associated with theprivacy campaign. In exemplary embodiments, the Risk Level may be anumerical number, as determined above by the Risk Assessment Module 430.If the organization chooses, the Privacy Audit Module 432 may use theOverall Risk Assessment to determine which audit schedule for thecampaign to assign.

At step 610, based on the Risk Level of the campaign (or the OverallRisk Assessment), or based on any other suitable factor, the PrivacyAudit Module 432 can assign an audit schedule for the campaign. Theaudit schedule may be, for example, a timeframe (i.e., a certain amountof time, such as number of days) until the next privacy audit on thecampaign to be performed by the one or more owners of the campaign. Theaudit schedule may be a default schedule. For example, the Privacy AuditModule can automatically apply an audit schedule of 120 days for anycampaign having Risk Level of 10 and above. These default schedules maybe modifiable. For example, the default audit schedule for campaignshaving a Risk Level of 10 and above can be changed from 120 days to 150days, such that any campaign having a Risk Level of 10 and above isassigned the customized default audit schedule (i.e., 150 days).Depending on privacy laws, default policies, authority overrides, or thepermission level of the user attempting to modify this default, thedefault might not be modifiable.

At step 615, after the audit schedule for a particular campaign hasalready been assigned, the Privacy Audit Module 432 determines if a userinput to modify the audit schedule has been received. If a user input tomodify the audit schedule has been received, then at step 620, thePrivacy Audit Module 432 determines whether the audit schedule for thecampaign is editable (i.e., can be modified). Depending on privacy laws,default policies, authority overrides, or the permission level of theuser attempting to modify the audit schedule, the campaign's auditschedule might not be modifiable.

At step 625, if the audit schedule is modifiable, then the Privacy AuditModule will allow the edit and modify the audit schedule for thecampaign. If at step 620 the Privacy Audit Module determines that theaudit schedule is not modifiable, in some exemplary embodiments, theuser may still request permission to modify the audit schedule. Forexample, the Privacy Audit Module 432 can at step 630 provide anindication that the audit schedule is not editable, but also provide anindication to the user that the user may contact through the system oneor more persons having the authority to grant or deny permission tomodify the audit schedule for the campaign (i.e., administrators) togain permission to edit the field. The Privacy Audit Module 432 maydisplay an on-screen button that, when selected by the user, sends anotification (e.g., an email) to an administrator. The user can thusmake a request to modify the audit schedule for the campaign in thismanner.

At step 635, the Privacy Audit Module may determine whether permissionhas been granted by an administrator to allow a modification to theaudit schedule. It may make this determination based on whether it hasreceived input from an administrator to allow modification of the auditschedule for the campaign. If the administrator has granted permission,the Privacy Audit Module 432 at step 635 may allow the edit of the auditschedule. If at step 640, a denial of permission is received from theadministrator, or if a certain amount of time has passed (which may becustomized or based on a default setting), the Privacy Audit Module 432retains the audit schedule for the campaign by not allowing anymodifications to the schedule, and the process may proceed to step 645.The Privacy Audit Module may also send a reminder to the administratorthat a request to modify the audit schedule for a campaign is pending.

At step 645, the Privacy Audit Module 432 determines whether a thresholdamount of time (e.g., number of days) until the audit has been reached.This threshold may be a default value, or a customized value. If thethreshold amount of time until an audit has been reached, the PrivacyAudit Module 432 may at step 650 generate an electronic alert. The alertcan be a message displayed to the collaborator the next time thecollaborator logs into the system, or the alert can be an electronicmessage sent to one or more collaborators, including the campaignowners. The alert can be, for example, an email, an instant message, atext message, or one or more of these communication modalities. Forexample, the message may state, “This is a notification that a privacyaudit for Campaign Internet Browsing History is scheduled to occur in 90days.” More than one threshold may be assigned, so that the owner of thecampaign receives more than one alert as the scheduled privacy auditdeadline approaches. If the threshold number of days has not beenreached, the Privacy Audit Module 432 will continue to evaluate whetherthe threshold has been reached (i.e., back to step 645).

In exemplary embodiments, after notifying the owner of the campaign ofan impending privacy audit, the Privacy Audit Module may determine atstep 655 whether it has received any indication or confirmation that theprivacy audit has been completed. In example embodiments, the PrivacyAudit Module allows for evidence of completion to be submitted, and ifsufficient, the Privacy Audit Module 432 at step 660 resets the counterfor the audit schedule for the campaign. For example, a privacy auditmay be confirmed upon completion of required electronic forms in whichone or more collaborators verify that their respective portions of theaudit process have been completed. Additionally, users can submitphotos, screen shots, or other documentation that show that theorganization is complying with that user's assigned portion of theprivacy campaign. For example, a database administrator may take ascreen shot showing that all personal data from the privacy campaign isbeing stored in the proper database and submit that to the system todocument compliance with the terms of the campaign.

If at step 655, no indication of completion of the audit has beenreceived, the Privacy Audit

Module 432 can determine at step 665 whether an audit for a campaign isoverdue (i.e., expired). If it is not overdue, the Privacy Audit Module432 will continue to wait for evidence of completion (e.g., step 655).If the audit is overdue, the Privacy Audit Module 432 at step 670generates an electronic alert (e.g., an email, instant message, or textmessage) to the campaign owner(s) or other administrators indicatingthat the privacy audit is overdue, so that the organization can takeresponsive or remedial measures.

In exemplary embodiments, the Privacy Audit Module 432 may also receivean indication that a privacy audit has begun (not shown), so that thestatus of the audit when displayed on inventory page 1500 shows thestatus of the audit as pending. While the audit process is pending, thePrivacy Audit Module 432 may be operable to generate reminders to besent to the campaign owner(s), for example, to remind the owner of thedeadline for completing the audit.

E. Data Flow Diagram Module

The system 110 may be operable to generate a data flow diagram based onthe campaign data entered and stored, for example in the mannerdescribed above.

I. Display of Security Indicators and Other Information

In various embodiments, a Data Flow Diagram Module is operable togenerate a flow diagram for display containing visual representations(e.g., shapes) representative of one or more parts of campaign dataassociated with a privacy campaign, and the flow of that informationfrom a source (e.g., customer), to a destination (e.g., an interne usagedatabase), to which entities and computer systems have access (e.g.,customer support, billing systems). Data Flow Diagram Module may alsogenerate one or more security indicators for display. The indicators mayinclude, for example, an “eye” icon to indicate that the data isconfidential, a “lock” icon to indicate that the data, and/or aparticular flow of data, is encrypted, or an “unlocked lock” icon toindicate that the data, and/or a particular flow of data, is notencrypted. In the example shown in FIG. 16, the dotted arrow linesgenerally depict respective flows of data and the locked or unlockedlock symbols indicate whether those data flows are encrypted orunencrypted. The color of dotted lines representing data flows may alsobe colored differently based on whether the data flow is encrypted ornon-encrypted, with colors conducive for viewing by those who sufferfrom color blindness.

II. Exemplary Process Performed by Data Flow Diagram Module

FIG. 7 shows an example process performed by the Data Flow DiagramModule 700. At step 705, the Data Flow Diagram retrieves campaign datarelated to a privacy campaign record. The campaign data may indicate,for example, that the sensitive information related to the privacycampaign contains confidential information, such as the social securitynumbers of a customer.

At step 710, the Data Flow Diagram Module 700 is operable to displayon-screen objects (e.g., shapes) representative of the Source,Destination, and Access, which indicate that information below theheading relates to the source of the personal data, the storagedestination of the personal data, and access related to the personaldata. In addition to campaign data regarding Source, Destination, andAccess, the Data Flow Diagram Module 700 may also account for userdefined attributes related to personal data, which may also be displayedas on-screen objects. The shape may be, for example, a rectangular box(see, e.g., FIG. 16). At step 715, the Data Flow Diagram Module 700 maydisplay a hyperlink label within the on-screen object (e.g., as shown inFIG. 16, the word “Customer” may be a hyperlink displayed within therectangular box) indicative of the source of the personal data, thestorage destination of the personal data, and access related to thepersonal data, under each of the respective headings. When a user hoversover the hyperlinked word, the Data Flow Diagram is operable to displayadditional campaign data relating to the campaign data associated withthe hyperlinked word. The additional information may also be displayedin a pop up, or a new page. For example, FIG. 16 shows that if a userhovers over the words “Customer,” the Data Flow Diagram Module 700displays what customer information is associated with the campaign(e.g., the Subscriber ID, the IP and Mac Addresses associated with theCustomer, and the customer's browsing and usage history). The Data FlowDiagram Module 700 may also generate for display information relating towhether the source of the data includes minors, and whether consent wasgiven by the source to use the sensitive information, as well as themanner of the consent (for example, through an End User LicenseAgreement (EULA)).

At step 720, the Data Flow Diagram Module 700 may display one or moreparameters related to backup and retention of personal data related tothe campaign, including in association with the storage destination ofthe personal data. As an example, Data Flow Diagram 1615 of FIG. 16displays that the information in the Internet Usage database is backedup, and the retention related to that data is Unknown.

At 725, the Data Flow Diagram Module 700 determines, based on thecampaign data associated with the campaign, whether the personal datarelated to each of the hyperlink labels is confidential. At Step 730, ifthe personal data related to each hyperlink label is confidential, theData Flow Diagram Module 700 generates visual indicator indicatingconfidentiality of that data (e.g., an “eye” icon, as show in Data FlowDiagram 1615). If there is no confidential information for that box,then at step 735, no indicators are displayed. While this is an exampleof the generation of indicators for this particular hyperlink, inexemplary embodiments, any user defined campaign data may visualindicators that may be generated for it.

At step 740, the Data Flow Diagram Module 700 determined whether any ofthe data associated with the source, stored in a storage destination,being used by an entity or application, or flowing to one or moreentities or systems (i.e., data flow) associated with the campaign isdesignated as encrypted. If the data is encrypted, then at step 745 theData Flow Diagram Module 700 may generate an indicator that the personaldata is encrypted (e.g., a “lock” icon). If the data is non-encrypted,then at step 750, the Data Flow Diagram Module 700 displays an indicatorto indicate that the data or particular flow of data is not encrypted.(e.g., an “unlocked lock” icon). An example of a data flow diagram isdepicted in FIG. 9. Additionally, the data flow diagram lines may becolored differently to indicate whether the data flow is encrypted orunencrypted, wherein the colors can still be distinguished by acolor-blind person.

F. Communications Module

In exemplary embodiments, a Communications Module of the System 100 mayfacilitate the communications between various owners and personnelrelated to a privacy campaign. The Communications Module may retaincontact information (e.g., emails or instant messaging contactinformation) input by campaign owners and other collaborators. TheCommunications Module can be operable to take a generated notificationor alert (e.g., alert in step 670 generated by Privacy Audit Module 432)and instantiate an email containing the relevant information. Asmentioned above, the Main Privacy Compliance Module 400 may, for examplethrough a communications module, be operable to send collaboratorsemails regarding their assignment of one or more portions of inputs tocampaign data. Or through the communications module, selecting thecommentators button brings up one or more collaborators that are on-line

In exemplary embodiments, the Communications Module can also, inresponse to a user request (e.g., depressing the “comment” button showin FIG. 9, FIG. 10, FIG. 11, FIG. 12, FIG. 13, FIG. 16), instantiate aninstant messaging session and overlay the instant messaging session overone or more portions of a GUI, including a GUI in which a user ispresented with prompts to enter or select information. An example ofthis instant messaging overlay feature orchestrated by theCommunications Module is shown in FIG. 14. While a real-time messagesession may be generated, off-line users may still able to see themessages when they are back on-line.

The Communications Module may facilitate the generation of alerts thatindicate that one or more emails or instant messages await acollaborator.

If campaign data inputs have been assigned to one or more collaborators,but those collaborators have not input the data yet, the CommunicationsModule, may facilitate the sending of an electronic message (such as anemail) alerting the collaborators and owners that they have not yetsupplied their designated portion of campaign data.

Exemplary User Experience

In the exemplary embodiments of the system for operationalizing privacycompliance, adding a campaign (i.e., data flow) comprises gatheringinformation that includes several phases: (1) a description of thecampaign; (2) the personal data to be collected as part of the campaign;(3) who the personal data relates to; (4) where the personal data bestored; and (5) who will have access to the indicated personal data.

A. FIG. 8: Campaign Record Creation and Collaborator Assignment

FIG. 8 illustrates an example of the first phase of informationgathering to add a campaign. In FIG. 8, a description entry dialog 800may have several fillable/editable fields and drop-down selectors. Inthis example, the user may fill out the name of the campaign in theShort Summary (name) field 805, and a description of the campaign in theDescription field 810. The user may enter or select the name of thebusiness group (or groups) that will be accessing personal data for thecampaign in the Business Group field 815. The user may select theprimary business representative responsible for the campaign (i.e., thecampaign's owner), and designate him/herself, or designate someone elseto be that owner by entering that selection through the Someone Elsefield 820. Similarly, the user may designate him/herself as the privacyoffice representative owner for the campaign, or select someone elsefrom the second Someone Else field 825. At any point, a user assigned asthe owner may also assign others the task of selecting or answering anyquestion related to the campaign. The user may also enter one or moretag words associated with the campaign in the Tags field 830. Afterentry, the tag words may be used to search for campaigns, or used tofilter for campaigns (for example, under Filters 845). The user mayassign a due date 835 for completing the campaign entry, and turnreminders for the campaign on or off. The user may save and continue, orassign and close.

In example embodiments, some of the fields may be filled in by a user,with suggest-as-you-type display of possible field entries (e.g.,Business Group field 815), and/or may include the ability for the userto select items from a drop-down selector (e.g., drop-down selectors 840a, 840 b, 840 c). The system may also allow some fields to stay hiddenor unmodifiable to certain designated viewers or categories of users.For example, the purpose behind a campaign may be hidden from anyone whois not the chief privacy officer of the company, or the retentionschedule may be configured so that it cannot be modified by anyoneoutside of the organization's′ legal department.

B. FIG. 9: Collaborator Assignment Notification and Description Entry

Moving to FIG. 9, in example embodiments, if another businessrepresentative (owner), or another privacy office representative hasbeen assigned to the campaign (e.g., John Doe in FIG. 8), the system maysend a notification (e.g., an electronic notification) to the assignedindividual, letting them know that the campaign has been assigned tohim/her. FIG. 9 shows an example notification 900 sent to John Doe thatis in the form of an email message. The email informs him that thecampaign “Internet Usage Tracking” has been assigned to him, andprovides other relevant information, including the deadline forcompleting the campaign entry and instructions to log in to the systemto complete the campaign (data flow) entry (which may be done, forexample, using a suitable “wizard” program). The user that assigned Johnownership of the campaign may also include additional comments 905 to beincluded with the notification 900. Also included may be an option toreply to the email if an assigned owner has any questions.

In this example, if John selects the hyperlink Privacy Portal 910, he isable to access the system, which displays a landing page 915. Thelanding page 915 displays a Getting Started section 920 to familiarizenew owners with the system, and also display an “About This Data Flow”section 930 showing overview information for the campaign.

C. FIG. 10: What Personal Data is Collected

Moving to FIG. 10, after the first phase of campaign addition (i.e.,description entry phase), the system may present the user (who may be asubsequently assigned business representative or privacy officer) with adialog 1000 from which the user may enter in the type of personal databeing collected.

In addition, questions are described generally as transitionalquestions, but the questions may also include one or more smartquestions in which the system is configured to: (1) pose an initialquestion to a user and, (2) in response to the user's answer satisfyingcertain criteria, presenting the user with one or more follow-upquestions. For example, in FIG. 10, if the user responds with a choiceto add personal data, the user may be additionally presented follow-upprompts, for example, the select personal data window overlaying screen800 that includes commonly used selections may include, for example,particular elements of an individual's contact information (e.g., name,address, email address), Financial/Billing Information (e.g., creditcard number, billing address, bank account number), Online Identifiers(e.g., IP Address, device type, MAC Address), Personal Details(Birthdate, Credit Score, Location), or Telecommunication Data (e.g.,Call History, SMS History, Roaming Status). The System 100 is alsooperable to pre-select or automatically populate choices—for example,with commonly-used selections 1005, some of the boxes may already bechecked. The user may also use a search/add tool 1010 to search forother selections that are not commonly used and add another selection.Based on the selections made, the user may be presented with moreoptions and fields. For example, if the user selected “Subscriber ID” aspersonal data associated with the campaign, the user may be prompted toadd a collection purpose under the heading Collection Purpose 1015, andthe user may be prompted to provide the business reason why a SubscriberID is being collected under the “Describe Business Need” heading 1020.

D. FIG. 11: Who Personal Data is Collected From

As displayed in the example of FIG. 11, the third phase of adding acampaign may relate to entering and selecting information regarding whothe personal data is gathered from. As noted above, the personal datamay be gathered from, for example, one or more Subjects 100. In theexemplary “Collected From” dialog 1100, a user may be presented withseveral selections in the “Who Is It Collected From” section 1105. Theseselections may include whether the personal data was to be collectedfrom an employee, customer, or other entity. Any entities that are notstored in the system may be added. The selections may also include, forexample, whether the data was collected from a current or prospectivesubject (e.g., a prospective employee may have filled out an employmentapplication with his/her social security number on it). Additionally,the selections may include how consent was given, for example through anend user license agreement (EULA), on-line Opt-in prompt, Impliedconsent, or an indication that the user is not sure. Additionalselections may include whether the personal data was collected from aminor, and where the subject is located.

E. FIG. 12: Where is the Personal Data Stored

FIG. 12 shows an example “Storage Entry” dialog screen 1200, which is agraphical user interface that a user may use to indicate whereparticular sensitive information is to be stored within the system. Fromthis section, a user may specify, in this case for the Internet UsageHistory campaign, the primary destination of the personal data 1220 andhow long the personal data is to be kept 1230. The personal data may behoused by the organization (in this example, an entity called “Acme”) ora third party. The user may specify an application associated with thepersonal data's storage (in this example, ISP Analytics), and may alsospecify the location of computing systems (e.g., servers) that will bestoring the personal data (e.g., a Toronto data center). Otherselections indicate whether the data will be encrypted and/or backed up.

The system also allows the user to select whether the destinationsettings are applicable to all the personal data of the campaign, orjust select data (and if so, which data). In FIG. 12, the user may alsoselect and input options related to the retention of the personal datacollected for the campaign (e.g., How Long Is It Kept 1230). Theretention options may indicate, for example, that the campaign'spersonal data should be deleted after a per-determined period of timehas passed (e.g., on a particular date), or that the campaign's personaldata should be deleted in accordance with the occurrence of one or morespecified events (e.g., in response to the occurrence of a particularevent, or after a specified period of time passes after the occurrenceof a particular event), and the user may also select whether backupsshould be accounted for in any retention schedule. For example, the usermay specify that any backups of the personal data should be deleted (or,alternatively, retained) when the primary copy of the personal data isdeleted.

F. FIG. 13: Who and What Systems Have Access to Personal Data

FIG. 13 describes an example Access entry dialog screen 1300. As part ofthe process of adding a campaign or data flow, the user may specify inthe “Who Has Access” section 1305 of the dialog screen 1300. In theexample shown, the Customer Support, Billing, and Government groupswithin the organization are able to access the Internet Usage Historypersonal data collected by the organization. Within each of these accessgroups, the user may select the type of each group, the format in whichthe personal data was provided, and whether the personal data isencrypted. The access level of each group may also be entered. The usermay add additional access groups via the Add Group button 1310.

G. Facilitating Entry of Campaign Data, Including Chat Shown in FIG. 14

As mentioned above, to facilitate the entry of data collected throughthe example GUIs shown in FIGS. 8 through 12, in exemplary embodiments,the system is adapted to allow the owner of a particular campaign (orother user) to assign certain sections of questions, or individualquestions, related to the campaign to contributors other than the owner.This may eliminate the need for the owner to contact other users todetermine information that they don't know and then enter theinformation into the system themselves. Rather, in various embodiments,the system facilitates the entry of the requested information directlyinto the system by the assigned users.

In exemplary embodiments, after the owner assigns a respectiveresponsible party to each question or section of questions that need tobe answered in order to fully populate the data flow, the system mayautomatically contact each user (e.g., via an appropriate electronicmessage) to inform the user that they have been assigned to complete thespecified questions and/or sections of questions, and provide thoseusers with instructions as to how to log into the system to enter thedata. The system may also be adapted to periodically follow up with eachuser with reminders until the user completes the designated tasks. Asdiscussed elsewhere herein, the system may also be adapted to facilitatereal-time text or voice communications between multiple collaborators asthey work together to complete the questions necessary to define thedata flow. Together, these features may reduce the amount of time andeffort needed to complete each data flow.

To further facilitate collaboration, as shown FIG. 14, in exemplaryembodiments, the System 100 is operable to overlay an instant messagingsession over a GUI in which a user is presented with prompts to enter orselect information. In FIG. 14, a communications module is operable tocreate an instant messaging session window 1405 that overlays the Accessentry dialog screen 1300. In exemplary embodiments, the CommunicationsModule, in response to a user request (e.g., depressing the “comment”button show in FIG. 9, FIG. 10, FIG. 11, FIG. 12, FIG. 13, FIG. 16),instantiates an instant messaging session and overlays the instantmessaging session over one or more portions of the GUI.

H: FIG. 15: Campaign Inventory Page

After new campaigns have been added, for example using the exemplaryprocesses explained in regard to FIGS. 8-13, the users of the system mayview their respective campaign or campaigns, depending on whether theyhave access to the campaign. The chief privacy officer, or anotherprivacy office representative, for example, may be the only user thatmay view all campaigns. A listing of all of the campaigns within thesystem may be viewed on, for example, inventory page 1500 (see below).Further details regarding each campaign may be viewed via, for example,campaign information page 1600, which may be accessed by selecting aparticular campaign on the inventory page 1500. And any informationrelated to the campaign may be edited or added through, for example, theedit campaign dialog 1700 screen (see FIG. 17). Certain fields orinformation may not be editable, depending on the particular user'slevel of access. A user may also add a new campaign using a suitableuser interface, such as the graphical user interface shown in FIG. 15 orFIG. 16.

In example embodiments, the System 100 (and more particularly, the MainPrivacy Compliance Module 400) may use the history of past entries tosuggest selections for users during campaign creation and entry ofassociated data. As an example, in FIG. 10, if most entries that containthe term “Internet” and have John Doe as the business rep assigned tothe campaign have the items Subscriber ID, IP Address, and MAC Addressselected, then the items that are commonly used may display aspre-selected items the Subscriber ID, IP address, and MAC Address eachtime a campaign is created having Internet in its description and JohnDoe as its business rep.

FIG. 15 describes an example embodiment of an inventory page 1500 thatmay be generated by the Main Privacy Compliance Module 400. Theinventory page 1500 may be represented in a graphical user interface.Each of the graphical user interfaces (e.g., webpages, dialog boxes,etc.) presented in this application may be, in various embodiments, anHTML-based page capable of being displayed on a web browser (e.g.,Firefox, Internet Explorer, Google Chrome, Opera, etc.), or any othercomputer-generated graphical user interface operable to displayinformation, including information having interactive elements (e.g., aniOS, Mac OS, Android, Linux, or Microsoft Windows application). Thewebpage displaying the inventory page 1500 may include typical featuressuch as a scroll-bar, menu items, as well as buttons for minimizing,maximizing, and closing the webpage. The inventory page 1500 may beaccessible to the organization's chief privacy officer, or any other ofthe organization's personnel having the need, and/or permission, to viewpersonal data.

Still referring to FIG. 15, inventory page 1500 may display one or morecampaigns listed in the column heading Data Flow Summary 1505, as wellas other information associated with each campaign, as described herein.Some of the exemplary listed campaigns include Internet Usage History1510, Customer Payment Information, Call History Log, Cellular RoamingRecords, etc. A campaign may represent, for example, a businessoperation that the organization is engaged in may require the use ofpersonal data, which may include the personal data of a customer. In thecampaign Internet Usage History 1510, for example, a marketingdepartment may need customers' on-line browsing patterns to runanalytics. Examples of more information that may be associated with theInternet Usage History 1510 campaign will be presented in FIG. 4 andFIG. 5. In example embodiments, clicking on (i.e., selecting) the columnheading Data Flow Summary 1505 may result in the campaigns being sortedeither alphabetically, or reverse alphabetically.

The inventory page 1500 may also display the status of each campaign, asindicated in column heading Status 1515. Exemplary statuses may include“Pending Review”, which means the campaign has not been approved yet,“Approved,” meaning the data flow associated with that campaign has beenapproved, “Audit Needed,” which may indicate that a privacy audit of thepersonal data associated with the campaign is needed, and “ActionRequired,” meaning that one or more individuals associated with thecampaign must take some kind of action related to the campaign (e.g.,completing missing information, responding to an outstanding message,etc.). In certain embodiments, clicking on (i.e., selecting) the columnheading Status 1515 may result in the campaigns being sorted by status.

The inventory page 1500 of FIG. 15 may list the “source” from which thepersonal data associated with a campaign originated, under the columnheading “Source” 1520. The sources may include one or more of thesubjects 100 in example FIG. 1. As an example, the campaign “InternetUsage History” 1510 may include a customer's IP address or MAC address.For the example campaign “Employee Reference Checks”, the source may bea particular employee. In example embodiments, clicking on (i.e.,selecting) the column heading Source 1520 may result in the campaignsbeing sorted by source.

The inventory page 1500 of FIG. 15 may also list the “destination” ofthe personal data associated with a particular campaign under the columnheading Destination 1525. Personal data may be stored in any of avariety of places, for example on one or more storage devices 280 thatare maintained by a particular entity at a particular location.Different custodians may maintain one or more of the different storagedevices. By way of example, referring to FIG. 15, the personal dataassociated with the Internet Usage History campaign 1510 may be storedin a repository located at the Toronto data center, and the repositorymay be controlled by the organization (e.g., Acme corporation) oranother entity, such as a vendor of the organization that has been hiredby the organization to analyze the customer's internet usage history.Alternatively, storage may be with a department within the organization(e.g., its marketing department). In example embodiments, clicking on(i.e., selecting) the column heading Destination 1525 may result in thecampaigns being sorted by destination.

On the inventory page 1500, the Access heading 1530 may show the numberof transfers that the personal data associated with a campaign hasundergone. In example embodiments, clicking on (i.e., selecting) thecolumn heading “Access” 1530 may result in the campaigns being sorted byAccess.

The column with the heading Audit 1535 shows the status of any privacyaudits associated with the campaign. Privacy audits may be pending, inwhich an audit has been initiated but yet to be completed. The auditcolumn may also show for the associated campaign how many days havepassed since a privacy audit was last conducted for that campaign.(e.g., 140 days, 360 days). If no audit for a campaign is currentlyrequired, an “OK” or some other type of indication of compliance (e.g.,a “thumbs up” indicia) may be displayed for that campaign's auditstatus. Campaigns may also be sorted based on their privacy audit statusby selecting or clicking on the Audit heading 1535.

In example inventory page 1500, an indicator under the heading Risk 1540may also display an indicator as to the Risk Level associated with thepersonal data for a particular campaign. As described earlier, a riskassessment may be made for each campaign based on one or more factorsthat may be obtained by the system. The indicator may, for example, be anumerical score (e.g., Risk Level of the campaign), or, as in theexample shown in FIG. 15, it may be arrows that indicate the OverallRisk Assessment for the campaign. The arrows may be of different shadesor different colors (e.g., red arrows indicating “high risk” campaigns,yellow arrows indicating “medium risk” campaigns, and green arrowsindicating “low risk” campaigns). The direction of the arrows—forexample, pointing upward or downward, may also provide a quickindication of Overall Risk Assessment for users viewing the inventorypage 1500. Each campaign may be sorted based on the Risk Levelassociated with the campaign.

The example inventory page 1500 may comprise a filter tool, indicated byFilters 1545, to display only the campaigns having certain informationassociated with them. For example, as shown in FIG. 15, under CollectionPurpose 1550, checking the boxes “Commercial Relations,” “ProvideProducts/Services”, “Understand Needs,” “Develop Business & Ops,” and“Legal Requirement” will result the display under the Data Flow Summary1505 of only the campaigns that meet those selected collection purposerequirements.

From example inventory page 1500, a user may also add a campaign byselecting (i.e., clicking on) Add Data Flow 1555. Once this selectionhas been made, the system initiates a routine to guide the user in aphase-by-phase manner through the process of creating a new campaign(further details herein). An example of the multi-phase GUIs in whichcampaign data associated with the added privacy campaign may be inputand associated with the privacy campaign record is described in FIG.8-13 above.

From the example inventory page 1500, a user may view the informationassociated with each campaign in more depth, or edit the informationassociated with each campaign. To do this, the user may, for example,click on or select the name of the campaign (i.e., click on InternetUsage History 1510). As another example, the user may select a buttondisplayed on screen indicating that the campaign data is editable (e.g.,edit button 1560).

I: FIG. 16: Campaign Information Page and Data Flow Diagram

FIG. 16 shows an example of information associated with each campaignbeing displayed in a campaign information page 1600. Campaigninformation page 1600 may be accessed by selecting (i.e., clicking on),for example, the edit button 1560. In this example, Personal DataCollected section 1605 displays the type of personal data collected fromthe customer for the campaign Internet Usage History. The type ofpersonal data, which may be stored as data elements associated with theInternet Usage History campaign digital record entry. The type ofinformation may include, for example, the customer's Subscriber ID,which may be assigned by the organization (e.g., a customeridentification number, customer account number). The type of informationmay also include data associated with a customer's premises equipment,such as an IP Address, MAC Address, URL History (i.e., websitesvisited), and Data Consumption (i.e., the number of megabytes orgigabytes that the user has download).

Still referring to FIG. 16, the “About this Data Flow” section 1610displays relevant information concerning the campaign, such as thepurpose of the campaign. In this example, a user may see that theInternet Usage History campaign is involved with the tracking ofinternet usage from customers in order to bill appropriately, manageagainst quotas, and run analytics. The user may also see that thebusiness group that is using the sensitive information associated withthis campaign is the Internet group. A user may further see that thenext privacy audit is scheduled for Jun. 10, 2016, and that the lastupdate of the campaign entry was Jan. 2, 2015. The user may also selectthe “view history” hyperlink to display the history of the campaign.

FIG. 16 also depicts an example of a Data Flow Diagram 1615 generated bythe system, based on information provided for the campaign. The DataFlow Diagram 1615 may provide the user with a large amount ofinformation regarding a particular campaign in a single compact visual.In this example, for the campaign Internet Usage History, the user maysee that the source of the personal data is the organization'scustomers. In example embodiments, as illustrated, hovering the cursor(e.g., using a touchpad, or a mouse) over the term “Customers” may causethe system to display the type of sensitive information obtained fromthe respective consumers, which may correspond with the informationdisplayed in the “Personal Data Collected” section 1605.

In various embodiments, the Data Flow Diagram 1615 also displays thedestination of the data collected from the User (in this example, anInternet Usage Database), along with associated parameters related tobackup and deletion. The Data Flow Diagram 1615 may also display to theuser which department(s) and what system(s) have access to the personaldata associated with the campaign. In this example, the Customer SupportDepartment has access to the data, and the Billing System may retrievedata from the Internet Usage Database to carry out that system'soperations. In the Data Flow Diagram 1615, one or more securityindicators may also be displayed. The may include, for example, an “eye”icon to indicate that the data is confidential, a “lock” icon toindicate that the data, and/or a particular flow of data, is encrypted,or an “unlocked lock” icon to indicate that the data, and/or aparticular flow of data, is not encrypted. In the example shown in FIG.16, the dotted arrow lines generally depict respective flows of data andthe locked or unlocked lock symbols indicate whether those data flowsare encrypted or unencrypted.

Campaign information page 1600 may also facilitate communications amongthe various personnel administrating the campaign and the personal dataassociated with it. Collaborators may be added through the Collaboratorsbutton 1625. The system may draw information from, for example, anactive directory system, to access the contact information ofcollaborators.

If comment 1630 is selected, a real-time communication session (e.g., aninstant messaging session) among all (or some) of the collaborators maybe instantiated and overlaid on top of the page 1600. This may behelpful, for example, in facilitating population of a particular page ofdata by multiple users. In example embodiments, the Collaborators 1625and Comments 1630 button may be included on any graphical user interfacedescribed herein, including dialog boxes in which information is enteredor selected. Likewise, any instant messaging session may be overlaid ontop of a webpage or dialog box. The system may also use the contactinformation to send one or more users associated with the campaignperiodic updates, or reminders. For example, if the deadline to finishentering the campaign data associated with a campaign is upcoming inthree days, the business representative of that assigned campaign may besent a message reminding him or her that the deadline is in three days.

Like inventory page 1500, campaign information page 1600 also allows forcampaigns to be sorted based on risk (e.g., Sort by Risk 1635). Thus,for example, a user is able to look at the information for campaignswith the highest risk assessment.

J: FIG. 17: Edit Campaign Dialog

FIG. 17 depicts an example of a dialog box—the edit campaign dialog1700. The edit campaign dialog 1700 may have editable fields associatedwith a campaign. In this example, the information associated with theInternet Usage History campaign may be edited via this dialog. Thisincludes the ability for the user to change the name of the campaign,the campaign's description, the business group, the current owner of thecampaign, and the particular personal data that is associated with thecampaign (e.g., IP address, billing address, credit score, etc.). Inexample embodiments, the edit campaign dialog 1700 may also allow forthe addition of more factors, checkboxes, users, etc.

The system 100 also includes a Historical Record Keeping Module, whereinevery answer, change to answer, as well as assignment/re-assignment ofowners and collaborators is logged for historical record keeping.

Automated Approach to Demonstrating Privacy by Design, and Integrationwith Software Development and Agile Tools for Privacy Design

In particular embodiments, privacy by design can be used in the designphase of a product (e.g., hardware or software), which is a documentedapproach to managing privacy risks. One of the primary concepts isevaluating privacy impacts, and making appropriate privacy-protectingchanges during the design of a project, before the project go-live.

In various embodiments, the system is adapted to automate this processwith the following capabilities: (1) initial assessment; (2) gapanalysis/recommended steps; and/or (3) final/updated assessment. Thesecapabilities are discussed in greater detail below.

Initial Assessment

In various embodiments, when a business team within a particularorganization is planning to begin a privacy campaign, the systempresents the business team with a set of assessment questions that aredesigned to help one or more members of the organization's privacy teamto understand what the business team's plans are, and to understandwhether the privacy campaign may have a privacy impact on theorganization. The questions may also include a request for the businessteam to provide the “go-live” date, or implementation date, for theprivacy campaign. In response to receiving the answers to thesequestions, the system stores the answers to the system's memory andmakes the answers available to the organization's privacy team. Thesystem may also add the “go-live” date to one or more electroniccalendars (e.g., the system's electronic docket).

In some implementations, the initial assessment can include an initialprivacy impact assessment that evaluates one or more privacy impactfeatures of the proposed design of the product. The initial privacyimpact assessment incorporates the respective answers for the pluralityof question/answer pairings in the evaluation of the one or more privacyimpact features. The privacy impact features may, for example, berelated to how the proposed design of the new product will collect, use,store, and/or manage personal data. One or more of these privacy impactfeatures can be evaluated, and the initial privacy assessment can beprovided to identify results of the evaluation.

Gap Analysis/Recommended Steps

After the system receives the answers to the questions, one or moremembers of the privacy team may review the answers to the questions. Theprivacy team may then enter, into the system, guidance and/orrecommendations regarding the privacy campaign. In some implementations,the privacy team may input their recommendations into the privacycompliance software. In particular embodiments, the system automaticallycommunicates the privacy team's recommendations to the business teamand, if necessary, reminds one or more members of the business team toimplement the privacy team's recommendations before the go-live date.The system may also implement one or more audits (e.g., as describedabove) to make sure that the business team incorporates the privacyteam's recommendations before the “go-live” date.

The recommendations may include one or more recommended steps that canbe related to modifying one or more aspects of how the product willcollect, use, store, and/or manage personal data. The recommended stepsmay include, for example: (1) limiting the time period that personaldata is held by the system (e.g., seven days); (2) requiring thepersonal data to be encrypted when communicated or stored; (3)anonymizing personal data; or (4) restricting access to personal data toa particular, limited group of individuals. The one or more recommendedsteps may be provided to address a privacy concern with one or more ofthe privacy impact features that were evaluated in the initial privacyimpact assessment.

In response to a recommended one or more steps being provided (e.g., bythe privacy compliance officers), the system may generate one or moretasks in suitable project management software that is used in managingthe proposed design of the product at issue. In various embodiments, theone or more tasks may be tasks that, if recommended, would individuallyor collectively complete one or more (e.g., all of) the recommendedsteps. For example, if the one or more recommended steps includerequiring personal data collected by the product to be encrypted, thenthe one or more tasks may include revising the product so that itencrypts any personal data that it collects.

The one or more tasks may include, for example, different steps to beperformed at different points in the development of the product. Inparticular embodiments, the computer software application may alsomonitor, either automatically or through suitable data inputs, thedevelopment of the product to determine whether the one or more taskshave been completed.

Upon completion of each respective task in the one or more tasks, thesystem may provide a notification that the task has been completed. Forexample, the project management software may provide a suitablenotification to the privacy compliance software that the respective taskhas been completed.

Final/Updated Assessment

Once the mitigation steps and recommendations are complete, the systemmay (e.g., automatically) conduct an updated review to assess anyprivacy risks associated with the revised product.

In particular embodiments, the system includes unique reporting andhistorical logging capabilities to automate Privacy-by-Design reportingand/or privacy assessment reporting. In various embodiments, the systemis adapted to: (1) measure/analyze the initial assessment answers fromthe business team; (2) measure recommendations for the privacy campaign;(3) measure any changes that were implemented prior to the go-live date;(4) automatically differentiate between: (a) substantive privacyprotecting changes, such as the addition of encryption, anonymization,or minimizations; and (b) non-substantive changes, such as spellingcorrection.

The system may also be adapted to generate a privacy assessment reportshowing that, in the course of a business's normal operations: (1) thebusiness evaluates projects prior to go-live for compliance with one ormore privacy-related regulations or policies; and (2) relatedsubstantive recommendations are made and implemented prior to go-live.This may be useful in documenting that privacy-by-design is beingeffectively implemented for a particular privacy campaign.

The privacy assessment report may, in various embodiments, include anupdated privacy impact assessment that evaluates the one or more privacyimpact features after the one or more recommended steps discussed aboveare implemented. The system may generate this updated privacy impactassessment automatically by, for example, automatically modifying anyanswers from within the question/answer pairings of the initial impactprivacy assessment to reflect any modifications to the product that havebeen made in the course of completing the one or more tasks thatimplement the one or more substantive recommendations. For example, if aparticular question from the initial privacy impact assessment indicatedthat certain personal data was personally identifiable data, and arecommendation was made to anonymize the data, the question/answerpairing for the particular question could be revised so the answer tothe question indicates that the data has been anonymized. Any revisedquestion/answer pairings may then be used to complete an updated privacyassessment report.

FIGS. 18A and 18B show an example process performed by a Data PrivacyCompliance Module 1800. In executing the Data Privacy Compliance Module1800, the system begins at Step 1802, where it presents a series ofquestions to a user (e.g., via a suitable computer display screen orother user-interface, such as a voice-interface) regarding the designand/or anticipated operation of the product. This may be done, forexample, by having a first software application (e.g., a data privacysoftware application or other suitable application) present the userwith a template of questions regarding the product (e.g., for use inconducting an initial privacy impact assessment for the product). Suchquestions may include, for example, data mapping questions and otherquestions relevant to the product's design and/or anticipated operation.

Next, the at Step 1804, the system receives, via a first computersoftware application, from a first set of one or more users (e.g.,product designers, such as software designers, or other individuals whoare knowledgeable about the product), respective answers to thequestions regarding the product and associates the respective answerswith their corresponding respective questions within memory to create aplurality of question/answer pairings regarding the proposed design ofthe product (e.g., software, a computerized electro-mechanical product,or other product).

Next, at Step 1806, the system presents a question to one or more usersrequesting the scheduled implantation date for the product. At Step1808, the system receives this response and saves the scheduledimplementation date to memory.

Next, after receiving the respective answers at Step 1804, the systemdisplays, at Step 1810, the respective answers (e.g., along with theirrespective questions and/or a summary of the respective questions) to asecond set of one or more users (e.g., one or more privacy officers fromthe organization that is designing the product), for example, in theform a plurality of suitable question/answer pairings. As an aside,within the context of this specification, pairings of an answer andeither its respective question or a summary of the question may bereferred to as a “question/answer” pairing. As an example, the question“Is the data encrypted? and respective answer “Yes” may be represented,for example, in either of the following question/answer pairings: (1)“The data is encrypted”; and (2) “Data encrypted? Yes”. Alternatively,the question/answer pairing may be represented as a value in aparticular field in a data structure that would convey that the data atissue is encrypted.

The system then advances to Step 1812, where it receives, from thesecond set of users, one or more recommended steps to be implemented aspart of the proposed design of the product and before the implementationdate, the one or more recommended steps comprising one or more stepsthat facilitate the compliance of the product with the one or moreprivacy standards and/or policies. In particular embodiments in whichthe product is a software application or an electro-mechanical devicethat runs device software, the one or more recommended steps maycomprise modifying the software application or device software to complywith one or more privacy standards and/or policies.

Next, at Step 1814, in response to receiving the one or more recommendedsteps, the system automatically initiates the generation of one or moretasks in a second computer software application (e.g., projectmanagement software) that is to be used in managing the design of theproduct. In particular embodiments, the one or more tasks comprise oneor more tasks that, if completed, individually and/or collectively wouldresult in the completion of the one or more recommended steps. Thesystem may do this, for example, by facilitating communication betweenthe first and second computer software applications via a suitableapplication programming interface (API).

The system then initiates a monitoring process for determining whetherthe one or more tasks have been completed. This step may, for example,be implemented by automatically monitoring which changes (e.g., edits tosoftware code) have been made to the product, or by receiving manualinput confirming that various tasks have been completed.

At Step 1816, the system receives a notification that the at least onetask has been completed. Finally, at Step 1818, at least partially inresponse to the first computer software application being provided withthe notification that the task has been completed, the system generatesan updated privacy assessment for the product that reflects the factthat the task has been completed. The system may generate this updatedprivacy impact assessment automatically by, for example, automaticallymodifying any answers from within the question/answer pairings of theinitial impact privacy assessment to reflect any modifications to theproduct that have been made in the course of completing the one or moretasks that implement the one or more substantive recommendations. Forexample, if a particular question from the initial privacy impactassessment indicated that certain personal data waspersonally-identifiable data, and a recommendation was made to anonymizethe data, the question/answer pairing for the particular question couldbe revised so that the answer to the question indicates that the datahas been anonymized. Any revised question/answer pairings may then beused to complete an updated privacy assessment report.

FIGS. 19A-19B depict the operation of a Privacy-By-Design Module 1900.In various embodiments, when the system executes the Privacy-By-DesignModule 1900, the system begins, at Step 1902, where it presents a seriesof questions to a user (e.g., via a suitable computer display screen orother user-interface, such as a voice-interface) regarding the designand/or anticipated operation of the product. This may be done, forexample, by having a first software application (e.g., a data privacysoftware application or other suitable application) present the userwith a template of questions regarding the product (e.g., for use inconducting an initial privacy impact assessment for the product). Suchquestions may include, for example, data mapping questions and otherquestions relevant to the product's design and/or anticipated operation.

Next, the at Step 1904, the system receives, e.g., via a first computersoftware application, from a first set of one or more users (e.g.,product designers, such as software designers, or other individuals whoare knowledgeable about the product), respective answers to thequestions regarding the product and associates the respective answerswith their corresponding respective questions within memory to create aplurality of question/answer pairings regarding the proposed design ofthe product (e.g., software, a computerized electro-mechanical product,or other product).

Next, at Step 1906, the system presents a question to one or more usersrequesting the scheduled implantation date for the product. At Step1908, the system receives this response and saves the scheduledimplementation date to memory.

Next, after receiving the respective answers at Step 1904, the systemdisplays, at Step 1910, the respective answers (e.g., along with theirrespective questions and/or a summary of the respective questions) to asecond set of one or more users (e.g., one or more privacy officers fromthe organization that is designing the product), for example, in theform a plurality of suitable question/answer pairings. As an aside,within the context of this specification, pairings of an answer andeither its respective question or a summary of the question may bereferred to as a “question/answer” pairing. As an example, the question“Is the data encrypted? and respective answer “Yes” may be represented,for example, in either of the following question/answer pairings: (1)“The data is encrypted”; and (2) “Data encrypted? Yes”. Alternatively,the question/answer pairing may be represented as a value in aparticular field in a data structure that would convey that the data atissue is encrypted.

The system then advances to Step 1912, where it receives, from thesecond set of users, one or more recommended steps to be implemented aspart of the proposed design of the product and before the implementationdate, the one or more recommended steps comprising one or more stepsthat facilitate the compliance of the product with the one or moreprivacy standards and/or policies. In particular embodiments in whichthe product is a software application or an electro-mechanical devicethat runs device software, the one or more recommended steps maycomprise modifying the software application or device software to complywith one or more privacy standards and/or policies.

Next, at Step 1914, in response to receiving the one or more recommendedsteps, the system automatically initiates the generation of one or moretasks in a second computer software application (e.g., projectmanagement software) that is to be used in managing the design of theproduct. In particular embodiments, the one or more tasks comprise oneor more tasks that, if completed, individually and/or collectively wouldresult in the completion of the one or more recommended steps.

The system then initiates a monitoring process for determining whetherthe one or more tasks have been completed. This step may, for example,be implemented by automatically monitoring which changes (e.g., edits tosoftware code) have been made to the product, or by receiving manualinput confirming that various tasks have been completed.

The system then advances to Step 1916, where it receives a notificationthat the at least one task has been completed. Next, at Step 1918, atleast partially in response to the first computer software applicationbeing provided with the notification that the task has been completed,the system generates an updated privacy assessment for the product thatreflects the fact that the task has been completed. The system maygenerate this updated privacy impact assessment automatically by, forexample, automatically modifying any answers from within thequestion/answer pairings of the initial impact privacy assessment toreflect any modifications to the product that have been made in thecourse of completing the one or more tasks that implement the one ormore substantive recommendations. For example, if a particular questionfrom the initial privacy impact assessment indicated that certainpersonal data was personally-identifiable data, and a recommendation wasmade to anonymize the data, the question/answer pairing for theparticular question could be revised so that the answer to the questionindicates that the data has been anonymized. Any revised question/answerpairings may then be used to complete an updated privacy assessmentreport.

As discussed above, at Step 1920, the system may then analyze the one ormore revisions that have made to the product to determine whether theone or more revisions substantively impact the product's compliance withone or more privacy standards. Finally, at Step 1922, the systemgenerates a privacy-by-design report that may, for example, include alisting of any of the one or more revisions that have been made and thatsubstantively impact the product's compliance with one or more privacystandards.

In various embodiments, the privacy-by-design report may also comprise,for example, a log of data demonstrating that the business, in thenormal course of its operations: (1) conducts privacy impact assessmentson new products before releasing them; and (2) implements any changesneeded to comply with one or more privacy polies before releasing thenew products. Such logs may include data documenting the results of anyprivacy impact assessments conducted by the business (and/or anyparticular sub-part of the business) on new products before eachrespective new product's launch date, any revisions that the business(and/or any particular sub-part of the business) make to new productsbefore the launch of the product. The report may also optionally includethe results of any updated privacy impact assessments conducted onproducts after the products have been revised to comply with one or moreprivacy regulations and/or policies. The report may further include alisting of any changes that the business has made to particular productsin response to initial impact privacy assessment results for theproducts. The system may also list which of the listed changes weredetermined, by the system, to be substantial changes (e.g., that thechanges resulted in advancing the product's compliance with one or moreprivacy regulations).

Additional Aspects of System

1. Standardized and Customized Assessment of Vendors' Compliance withPrivacy and/or Security Policies

In particular embodiments, the system may be adapted to: (1) facilitatethe assessment of one or more vendors' compliance with one or moreprivacy and/or security policies; and (2) allow organizations (e.g.,companies or other organizations) who do business with the vendors tocreate, view and/or apply customized criteria to informationperiodically collected by the system to evaluate each vendor'scompliance with one or more of the company's specific privacy and/orsecurity policies. In various embodiments, the system may also flag anyassessments, projects, campaigns, and/or data flows that theorganization has documented and maintained within the system if thosedata flows are associated with a vendor that has its rating changed sothat the rating meets certain criteria (e.g., if the vendor's ratingfalls below a predetermined threshold).

In particular embodiments:

-   -   The system may include an online portal and community that        includes a listing of all supported vendors.    -   An appropriate party (e.g., the participating vendor or a member        of the on-line community) may use the system to submit an        assessment template that is specific to a particular vendor.        -   If the template is submitted by the vendor itself, the            template may be tagged in any appropriate way as “official”        -   An instance for each organization using the system (i.e.,            customer) is integrated with this online community/portal so            that the various assessment templates can be directly fed            into that organization's instance of the system if the            organization wishes to use it.    -   Vendors may subscribe to a predetermined standardized assessment        format.        -   Assessment results may also be stored in the central            community/portal.        -   A third-party privacy and/or security policy compliance            assessor, on a schedule, may (e.g., periodically) complete            the assessment of the vendor.        -   Each organization using the system can subscribe to the            results (e.g., once they are available).        -   Companies can have one or more customized rules set up            within the system for interpreting the results of            assessments in their own unique way. For example:            -   Each customer can weight each question within an                assessment as desired and set up addition/multiplication                logic to determine an aggregated risk score that takes                into account the customized weightings given to each                question within the assessment.            -   Based on new assessment results—the system may notify                each customer if the vendor's rating falls, improves, or                passes a certain threshold.            -   The system can flag any assessments, projects,                campaigns, and/or data flows that the customer has                documented and maintained within the system if those                data flows are associated with a vendor that has its                rating changed.                2. Privacy Policy Compliance System that Facilitates                Communications with Regulators (Including Translation                Aspect)

In particular embodiments, the system is adapted to interface with thecomputer systems of regulators (e.g., government regulatory agencies)that are responsible for approving privacy campaigns. This may, forexample, allow the regulators to review privacy campaign informationdirectly within particular instances of the system and, in someembodiments, approve the privacy campaigns electronically.

In various embodiments, the system may implement this concept by:

-   -   Exporting relevant data regarding the privacy campaign, from an        organization's instance of the system (e.g., customized version        of the system) in standardized format (e.g., PDF or Word) and        sending the extracted data to an appropriate regulator for        review (e.g., in electronic or paper format).        -   Either regular provides the format that the system codes to,            or the organization associated with the system provides a            format that the regulators are comfortable with.    -   Send secure link to regulator that gives them access to comment        and leave feedback        -   Gives the regulator direct access to the organization's            instance of the system with a limited and restricted view of            just the projects and associated audit and commenting logs            the organization needs reviewed.        -   Regulator actions are logged historically and the regulator            can leave guidance, comments, and questions, etc.    -   Have portal for regulator that securely links to the systems of        their constituents.

Details:

-   -   When submitted—the PIAs are submitted with requested        priority—standard or expedited.    -   DPA specifies how many expedited requests individuals are        allowed to receive.    -   Either the customer or DPA can flag a PIA or associated        comments/guidance on the PIA with “needs translation” and that        can trigger an automated or manual language translation.    -   Regulator could be a DPA “data protection authority” in any EU        country, or other country with similar concept like FTC in US,        or OPC in Canada.        3. Systems/Methods for Measuring the Privacy Maturity of a        Business Group within an Organization.

In particular embodiments, the system is adapted for automaticallymeasuring the privacy of a business group, or other group, within aparticular organization that is using the system. This may provide anautomated way of measuring the privacy maturity, and one or more trendsof change in privacy maturity of the organization, or a selectedsub-group of the organization.

In various embodiments, the organization using the system can customizeone or more algorithms used by the system to measure the privacymaturity of a business group (e.g., by specifying one or more variablesand/or relative weights for each variable in calculating a privacymaturity score for the group). The following are examples of variablesthat may be used in this process:

-   -   Issues/Risks found in submitted assessments that are unmitigated        or uncaught prior to the assessment being submitted to the        privacy office        -   % of privacy assessments with high issues/total assessments        -   % with medium        -   % with low    -   Size and type of personal data used by the group        -   Total assessments done        -   Number of projects/campaigns with personal data        -   Amount of personal data        -   Volume of data transfers to internal and external parties    -   Training of the people in the group        -   Number or % of individuals who have watched training,            readings, or videos        -   Number or % of individuals who have completed quizzes or            games for privacy training        -   Number or % of individuals who have attended privacy events            either internally or externally        -   Number or % of individuals who are members of IAPP        -   Number or % of individuals who have been specifically            trained in privacy either internally or externally, formally            (IAPP certification) or informally        -   Usage of an online version of the system, or mobile training            or communication portal that customer has implemented    -   Other factors        4. Automated Assessment of Compliance (Scan App or Website to        Determine Behavior/Compliance with Privacy Policies)

In various embodiments, instead of determining whether an organizationcomplies with the defined parameters of a privacy campaign by, forexample, conducting an audit as described above (e.g., by asking usersto answer questions regarding the privacy campaign, such as “What iscollected” “what cookies are on your website”, etc.), the system may beconfigured to automatically determine whether the organization iscomplying with one or more aspects of the privacy policy.

For example, during the audit process, the system may obtain a copy of asoftware application (e.g., an “app”) that is collecting and/or usingsensitive user information, and then automatically analyze the app todetermine whether the operation of the app is complying with the termsof the privacy campaign that govern use of the app.

Similarly, the system may automatically analyze a website that iscollecting and/or using sensitive user information to determine whetherthe operation of the web site is complying with the terms of the privacycampaign that govern use of the web site.

In regard to various embodiments of the automatic application-analyzingembodiment referenced above:

-   -   The typical initial questions asked during an audit may be        replaced by a request to “Upload your app here”.        -   After the app is uploaded to the system, the system detects            what privacy permissions and data the app is collecting from            users.        -   This is done by having the system use static or behavioral            analysis of the application, or by having the system            integrate with a third-party system or software (e.g.,            Veracode), which executes the analysis.        -   During the analysis of the app, the system may detect, for            example, whether the app is using location services to            detect the location of the user's mobile device.        -   In response to determining that the app is collecting one or            more specified types of sensitive information (e.g., the            location of the user's mobile device), the system may            automatically request follow up information from the user by            posing one or more questions to the user, such as:            -   For what business reason is the data being collected?            -   How is the user's consent given to obtain the data?            -   Would users be surprised that the data is being                collected?            -   Is the data encrypted at rest and/or in motion?            -   What would happen if the system did not collect this                data? What business impact would it have?            -   In various embodiments, the system is adapted to allow                each organization to define these follow-up questions,                but the system asks the questions (e.g., the same                questions, or a customized list of questions) for each                privacy issue that is found in the app.        -   In various embodiments, after a particular app is scanned a            first time, when the app is scanned, the system may only            detect and analyze any changes that have been made to the            app since the previous scan of the app.        -   In various embodiments, the system is adapted to            (optionally) automatically monitor (e.g., continuously            monitor) one or more online software application            marketplaces (such as Microsoft, Google, or Apple's App            Store) to determine whether the application has changed. If            so, the system may, for example: (1) automatically scan the            application as discussed above; and (2) automatically notify            one or more designated individuals (e.g., privacy office            representatives) that an app was detected that the business            failed to perform a privacy assessment on prior to launching            the application.

In regard to various embodiments of the automatic application-analyzingembodiment referenced above:

-   -   The system prompts the user to enter the URL of the web site to        be analyzed, and, optionally, the URL to the privacy policy that        applies to the web site.    -   The system then scans the website for cookies, and/or other        tracking mechanisms, such as fingerprinting technologies and/or        3rd party SDKs.        -   The system may then optionally ask the user to complete a            series of one or more follow-up questions for each of these            items found during the scan of the website.        -   This may help the applicable privacy office craft a privacy            policy to be put on the website to disclose the use of the            tracking technologies and SDK's used on the website.    -   The system may then start a continuous monitoring of the website        site to detect whether any new cookies, SDKs, or tracking        technologies are used. In various embodiments, the system is        configured to, for example, generate an alert to an appropriate        individual (e.g., a designated privacy officer) to inform them        of the change to the website. The privacy officer may use this        information, for example, to determine whether to modify the        privacy policy for the website or to coordinate discontinuing        use of the new tracking technologies and/or SDK's.    -   In various embodiments, the system may also auto-detect whether        any changes have been made to the policy or the location of the        privacy policy link on the page and, in response to        auto-detecting such changes, trigger an audit of the project.    -   It should be understood that the above methods of automatically        assessing behavior and/or compliance with one or more privacy        policies may be done in any suitable way (e.g., ways other than        website scanning and app scanning). For example, the system may        alternatively, or in addition, automatically detect, scan and/or        monitor any appropriate technical system(s) (e.g., computer        system and/or system component or software), cloud services,        apps, websites and/or data structures, etc.        5. System Integration with DLP Tools.

DLP tools are traditionally used by information security professionals.Various DLP tools discover where confidential, sensitive, and/orpersonal information is stored and use various techniques toautomatically discover sensitive data within a particular computersystem—for example, in emails, on a particular network, in databases,etc. DLP tools can detect the data, what type of data, the amount ofdata, and whether the data is encrypted. This may be valuable forsecurity professionals, but these tools are typically not useful forprivacy professionals because the tools typically cannot detect certainprivacy attributes that are required to be known to determine whether anorganization is in compliance with particular privacy policies.

For example, traditional DLP tools cannot typically answer the followingquestions:

-   -   Who was the data collected from (data subject)?    -   Where are those subjects located?    -   Are they minors?    -   How was consent to use the data received?    -   What is the use of the data?    -   Is the use consistent with the use specified at the time of        consent?    -   What country is the data stored in and/or transferred to?    -   Etc.    -   In various embodiments, the system is adapted to integrate with        appropriate DLP and/or data discovery tools (e.g., INFORMATICA)        and, in response to data being discovered by those tools, to        show each area of data that is discovered as a line-item in a        system screen via integration.    -   The system may do this, for example, in a manner that is similar        to pending transactions in a checking account that have not yet        been reconciled.    -   A designated privacy officer may then select one of those—and        either match it up (e.g., reconcile it) with an existing data        flow or campaign in the system OR trigger a new assessment to be        done on that data to capture the privacy attributes and data        flow.

6. System for Generating an Organization'S Data Map by Campaign, bySystem, or by Individual Data Attributes.

In particular embodiments, the system may be adapted to allow users tospecify various criteria, and then to display, to the user, any datamaps that satisfy the specified criteria. For example, the system may beadapted to display, in response to an appropriate request: (1) all of aparticular customer's data flows that are stored within the system; (2)all of the customer's data flows that are associated with a particularcampaign; and/or (3) all of the customer's data flows that involve aparticular address.

Similarly, the system may be adapted to allow privacy officers todocument and input the data flows into the system in any of a variety ofdifferent ways, including:

-   -   Document by process        -   The user initiates an assessment for a certain business            project and captures the associated data flows (including            the data elements related to the data flows and the systems            they are stored in).    -   Document by element        -   The user initiates an audit of a data element—such as            SSN—and tries to identify all data structures associated            with the organization that include the SSN. The system may            then document this information (e.g., all of the            organization's systems and business processes that involve            the business processes.)    -   Document by system        -   The user initiates an audit of a database, and the system            records, in memory, the results of the audit.            7. Privacy Policy Compliance System that Allows Users to            Attach Emails to Individual Campaigns.

Privacy officers frequently receive emails (or other electronicmessages) that are associated with an existing privacy assessment orcampaign, or a potential future privacy assessment. For record keepingand auditing purposes, the privacy officer may wish to maintain thoseemails in a central storage location, and not in email. In variousembodiments, the system is adapted to allow users to automaticallyattach the email to an existing privacy assessment, data flow, and/orprivacy campaign. Alternatively or additionally, the system may allow auser to automatically store emails within a data store associated withthe system, and to store the emails as “unassigned”, so that they maylater be assigned to an existing privacy assessment, data flow, and/orprivacy campaign.

-   -   In various embodiments, the system is adapted to allow a user to        store an email using:        -   a browser plugin-extension that captures webmail;        -   a Plug-in directly with office 365 or google webmail (or            other suitable email application);        -   a Plug-in with email clients on computers such as Outlook;        -   via an integrated email alias that the email is forwarded            to; or        -   any other suitable configuration

8. Various Aspects of Related Mobile Applications

In particular embodiments, the system may use a mobile app (e.g., thatruns on a particular mobile device associated by a user) to collect datafrom a user. The mobile app may be used, for example, to collect answersto screening questions. The app may also be adapted to allow users toeasily input data documenting and/or reporting a privacy incident. Forexample, the app may be adapted to assist a user in using their mobiledevice to capture an image of a privacy incident (e.g., a screen shotdocumenting that data has been stored in an improper location, or that aprintout of sensitive information has been left in a public workspacewithin an organization.)

The mobile app may also be adapted to provide incremental training toindividuals. For example, the system may be adapted to provideincremental training to a user (e.g., in the form of the presentation ofshort lessons on privacy). Training sessions may be followed by shortquizzes that are used to allow the user to assess their understanding ofthe information and to confirm that they have completed the training.

9. Automatic Generation of Personal Data Inventory for Organization

In particular embodiments, the system is adapted to generate and displayan inventory of the personal data that an organization collects andstores within its systems (or other systems). As discussed above, invarious embodiments, the system is adapted to conduct privacy impactassessments for new and existing privacy campaigns. During a privacyimpact assessment for a particular privacy campaign, the system may askone or more users a series of privacy impact assessment questionsregarding the particular privacy campaign and then store the answers tothese questions in the system's memory, or in memory of another system,such a third-party computer server.

Such privacy impact assessment questions may include questionsregarding: (1) what type of data is to be collected as part of thecampaign; (2) who the data is to be collected from; (3) where the datais to be stored; (4) who will have access to the data; (5) how long thedata will be kept before being deleted from the system's memory orarchived; and/or (6) any other relevant information regarding thecampaign.

The system may store the above information, for example, in any suitabledata structure, such as a database. In particular embodiments, thesystem may be configured to selectively (e.g., upon request by anauthorized user) generate and display a personal data inventory for theorganization that includes, for example, all of the organization'scurrent active campaigns, all of the organization's current and pastcampaigns, or any other listing of privacy campaigns that, for example,satisfy criteria specified by a user. The system may be adapted todisplay and/or export the data inventory in any suitable format (e.g.,in a table, a spreadsheet, or any other suitable format).

10. Integrated/Automated Solution for Privacy Risk Assessments

Continuing with Concept 9, above, in various embodiments, the system mayexecute multiple integrated steps to generate a personal data inventoryfor a particular organization. For example, in a particular embodiment,the system first conducts a Privacy Threshold Assessment (PTA) by askinga user a relatively short set of questions (e.g., between 1 and 15questions) to quickly determine whether the risk associated with thecampaign may potentially exceed a pre-determined risk threshold (e.g.,whether the campaign is a potentially high-risk campaign). The systemmay do this, for example, by using any of the above techniques to assigna collective risk score to the user's answers to the questions anddetermining whether the collective risk score exceeds a particular riskthreshold value. Alternatively, the system may be configured todetermine that the risk associated with the campaign exceeds the riskthreshold value if the user answers a particular one or more of thequestions in a certain way.

The system may be configured for, in response to the user's answers toone or more of the questions within the Privacy Threshold Assessmentindicating that the campaign exceeds, or may potentially exceed, apre-determined risk threshold, presenting the user with a longer set ofdetailed questions regarding the campaign (e.g., a Privacy ImpactAssessment). The system may then use the user's answers to this longerlist of questions to assess the overall risk of the campaign, forexample, as described above.

In particular embodiments, the system may be configured for, in responseto the user's answers to one or more of the questions within the PrivacyThreshold Assessment indicating that the campaign does not exceed, ordoes not potentially exceed, a pre-determined risk threshold, notpresenting the user with a longer set of detailed questions regardingthe campaign (e.g., a Privacy Impact Assessment). In such a case, thesystem may simply save an indication to memory that the campaign is arelatively low risk campaign.

Accordingly, in particular embodiments, the system may be adapted toautomatically initiate a Privacy Impact Assessment if the results of ashorter Privacy Threshold Assessment satisfy certain criteria.Additionally, or alternatively, in particular embodiments, the systemmay be adapted to allow a privacy officer to manually initiate a PrivacyImpact Assessment for a particular campaign.

In particular embodiments, built into the Privacy Threshold Assessmentand the Privacy

Impact Assessment are the data mapping questions and/or sub-questions ofhow the personal data obtained through the campaign will be collected,used, stored, accessed, retained, and/or transferred, etc. In particularembodiments: (1) one or more of these questions are asked in the PrivacyThreshold Assessment; and (2) one or more of the questions are asked inthe Privacy Impact Assessment. In such embodiments, the system mayobtain the answers to each of these questions, as captured during thePrivacy Threshold Assessment and the Privacy Impact Assessment, and thenuse the respective answers to generate the end-to-end data flow for therelevant privacy campaign.

The system may then link all of the data flows across all of theorganization's privacy campaigns together in order to show a completeevergreen version of the personal data inventory of the organization.Thus, the system may efficiently generate the personal data inventory ofan organization (e.g., through the use of reduced computer processingpower) by automatically gathering the data needed to prepare thepersonal data inventory while conducting Privacy Threshold Assessmentsand Privacy Impact Assessments.

System for Preventing Individuals from Trying to Game the System

As discussed above, in particular embodiments, the system is adapted todisplay a series of threshold questions for particular privacy campaignsand to use conditional logic to assess whether to present additional,follow-up questions to the user. There may, for example, be situationsin which a user may answer, or attempt to answer, one or more of thethreshold questions incorrectly (e.g., dishonestly) in an attempt toavoid needing to answer additional questions. This type of behavior canpresent serious potential problems for the organization because thebehavior may result in privacy risks associated with a particularprivacy campaign being hidden due to the incorrect answer or answers.

To address this issue, in various embodiments, the system maintains ahistorical record of every button press (e.g., un-submitted systeminput) that an individual makes when a question is presented to them. Inparticular embodiments, actively monitoring the user's system inputs mayinclude, for example, monitoring, recording, tracking, and/or otherwisetaking account of the user's system inputs. These system inputs mayinclude, for example: (1) one or more mouse inputs; (2) one or morekeyboard (e.g., text) inputs); (3) one or more touch inputs; and/or (4)any other suitable inputs (e.g., such as one or more vocal inputs,etc.). In various embodiments, the system is configured to activelymonitor the user's system inputs, for example: (1) while the user isviewing one or more graphical user interfaces for providing informationregarding or responses to questions regarding one or more privacycampaigns; (2) while the user is logged into a privacy portal; and/or(3) in any other suitable situation related to the user providinginformation related to the collection or storage of personal data (e.g.,in the context of a privacy campaign). Additionally, the system tracks,and saves to memory, each incidence of the individual changing theiranswer to a question (e.g., (a) before formally submitting the answer bypressing an “enter” key, or other “submit” key on a user interface, suchas a keyboard or graphical user interface on a touch-sensitive displayscreen; or (b) after initially submitting the answer).

The system may also be adapted to automatically determine whether aparticular question (e.g., threshold question) is a “critical” questionthat, if answered in a certain way, would cause the conditional logictrigger to present the user with one or more follow-up questions. Forexample, the system may, in response to receiving the user's full set ofanswers to the threshold questions, automatically identify anyindividual question within the series of threshold questions that, ifanswered in a particular way (e.g., differently than the user answeredthe question) would have caused the system to display one or more followup questions. The system may then flag those identified questions, inthe system's memory, as “critical” questions.

Alternatively, the system may be adapted to allow a user (e.g., aprivacy officer of an organization) who is drafting a particularthreshold question that, when answered in a particular way, willautomatically trigger the system to display one or more follow upquestions to the user, to indicate that is a “critical” thresholdquestion. The system may then save this “critical” designation of thequestion to the system's computer memory.

In various embodiments, the system is configured, for any questions thatare deemed “critical” (e.g., either by the system, or manually, asdiscussed above), to determine whether the user exhibited any abnormalbehavior when answering the question. For example, the system may checkto see whether the user changed their answer once, or multiple times,before submitting their answer to the question (e.g., by tracking theuser's keystrokes while they are answering the threshold question, asdescribed above). As another example, the system may determine whetherit took the user longer than a pre-determined threshold amount of time(e.g., 5 minutes, 3 minutes, etc . . . ) to answer the criticalthreshold question.

In particular embodiments, the system may be adapted, in response todetermining that the user exhibited abnormal behavior when answering thecritical threshold question, to automatically flag the thresholdquestion and the user's answer to that question for later follow up by adesignated individual or team (e.g., a member of the organization'sprivacy team). In particular embodiments, the system may also, oralternatively, be adapted to automatically generate and transmit amessage to one or more individuals (e.g., the organization's chiefprivacy officer) indicating that the threshold question may have beenanswered incorrectly and that follow-up regarding the question may beadvisable. After receiving the message, the individual may, inparticular embodiments, follow up with the individual who answered thequestion, or conduct other additional research, to determine whether thequestion was answered accurately.

In particular embodiments, the system is configured to monitor a user'scontext as the user provides responses for a computerized privacyquestionnaire. The user context may take in to account a multitude ofdifferent user factors to incorporate information about the user'ssurroundings and circumstances. One user factor may be the amount oftime a user takes to respond to one or more particular questions or thecomplete computerized privacy questionnaire. For example, if the userrushed through the computerized privacy questionnaire, the system mayindicate that user abnormal behavior occurred in providing the one ormore responses. In some implementations, the system may include athreshold response time for each question of the computerized privacyquestionnaire (e.g., this may be a different threshold response time foreach question) or the complete computerized privacy questionnaire. Thesystem may compare the response time for each of the one or moreresponses to its associated threshold response time, and/or the systemmay compare the response time for completion of the computerized privacyquestionnaire to the associated threshold response time for completionof the full computerized privacy questionnaire. The system may beconfigured to indicate that user abnormal behavior occurred in providingthe one or more responses when either the response time is a longerperiod of time (e.g., perhaps indicating that the user is beingdishonest) or shorter period of time (e.g., perhaps indicating that theuser is rushing through the computerized privacy questionnaire and theresponses may be inaccurate) than the threshold response time.

Another user factor may be a deadline for initiation or completion ofthe computerized privacy questionnaire. For example, if the userinitiated or completed the computerized privacy questionnaire after aparticular period of time (e.g., an initiation time or a completiontime), the system may indicate that user abnormal behavior occurred inproviding the one or more responses. The certain period of time may bepreset, user-defined, and/or adjusted by the user, and may be athreshold time period. Additionally, in some implementations, the userfactors may be adjusted based on one another. For example, if the userinitiated the computerized privacy questionnaire close to a deadline forthe computerized privacy questionnaire, then the threshold response timefor each question of the computerized privacy questionnaire or thecomplete computerized privacy questionnaire may be modified (e.g., thethreshold response time may be increased to ensure that the user doesnot rush through the privacy questionnaire close to the deadline).

Additionally, another user factor may incorporate a location in whichthe user conducted the privacy questionnaire. For example, if the userconducted the privacy questionnaire in a distracting location (e.g., atthe movies or airport), the system may indicate that user abnormalbehavior occurred. The system may use GPS tracking data associated withthe electronic device (e.g., laptop, smart phone) on which the userconducted the privacy questionnaire to determine the location of theuser. The system may include one or more particular locations or typesof locations that are designated as locations in which the user may bedistracted, or otherwise provide less accurate results. The locationsmay be specific to each user or the same locations for all users, andthe locations may be adjusted (e.g., added, removed, or otherwisemodified). The types of locations may be locations such as restaurants,entertainment locations, mass transportation points (e.g., airports,train stations), etc.

In particular embodiments, the system is configured to determine a typeof connection via which the user is accessing the questionnaire. Forexample, the system may determine that the user is accessing thequestionnaire while connect to a public wireless network (e.g., at anairport, coffee shop, etc.). The system may further determine that theuser is connect to a wireless or other network such as a home network(e.g., at the user's house). In such examples, the system may determinethat the user may be distracted based on a location inferred based onone or more connections identified for the computing device via whichthe user is accessing the questionnaire. In other embodiments, thesystem may determine that the user is connect via a company network(e.g., a network associated with the entity providing the questionnairefor completion). In such embodiments, the system may be configured todetermine that the user is focused on the questionnaire (e.g., by virtueof the user being at work while completing it).

Moreover, another user factor may involve determining the electronicactivities the user is performing on the user's electronic device whilethey are completing the privacy questionnaire. This factor may also berelated to determining if the user is distracted when completing theprivacy questionnaire. For example, the system may determine whether theuser interacted, on the electronic device, with one or more web browsersor software applications that are unrelated to conducting thecomputerized privacy questionnaire (e.g., by determining whether theuser accessed one or more other active browsing windows, or whether abrowsing window in which the user is completing the questionnairebecomes inactive while the user us completing it). If the systemdetermines that such unrelated electronic activities were interactedwith, the system may indicate that user abnormal behavior occurred incompleting the privacy questionnaire. Further, the electronic activitiesmay be preset, user-specific, and/or modified. The user factors aboveare provided by way of example, and more, fewer, or different userfactors may be included as part of the system. In some embodiments, thesystem may incorporate the user's electronic device camera to determineif the user is exhibiting abnormal behavior (e.g., pupilsdilated/blinking a lot could indicate deception in responding to theprivacy questionnaire).

In some implementations, the system may use one or more of the userfactors to calculate a user context score. Each of the user factors mayinclude a user factor rating to indicate a likelihood that user abnormalbehavior occurred with respect to that particular user factor. The usercontext score may be calculated based on each of the user factorratings. In some embodiments, a weighting factor may be applied to eachuser factor (e.g., this may be specific for each organization) for thecalculation of the user context score. Additionally, in someembodiments, if one or more user factor ratings is above a certainrating (i.e., indicating a very likelihood of user abnormal behavior forthat particular user factor), then the user context score mayautomatically indicate that user abnormal behavior occurred incompleting the privacy questionnaire. The user context score may becompared to a threshold user context score that may be preset, user ororganization defined, and/or modified. If the system determines that theuser context score is greater than the threshold user context score(i.e., indicates a higher likelihood of user abnormal behavior than thelikelihood defined by threshold), then the system may indicate that userabnormal behavior occurred in conducting the privacy questionnaire.

In some implementations, the submitted input of the user to one or moreresponses may include a particular type of input that may cause thesystem to provide one or more follow up questions. The follow upquestions may be provided for the user justify the particular type ofinput response that was provided. The particular type of input may beresponses that are indefinite, indicate the user is unsure of theappropriate response (e.g., “I do not know”), or intimate that the useris potentially being untruthful in the response. For example, if theuser provides a response of “I do not know” (e.g., by selecting in alist or inputting in a text box), the system may be configured toprovided one or more follow up questions to further determine why theuser “does not know” the answer to the specific inquiry or if the useris being truthful is saying they “do not know.”

In some implementations, the system may, for each of the one or moreresponses to one or more questions in the computerized privacyquestionnaire, determine a confidence factor score. The confidencefactor score may be based on the user context of the user as the userprovides the one or more responses and/or the one or more system inputsfrom the user the comprise the one or more responses. For example, ifthe user was in a distracting environment when the user provided aparticular response in the privacy questionnaire and/or the userprovided one or more unsubmitted inputs prior to providing the submittedinput for the particular response, the system may calculate a lowconfidence factor score for the particular response.

Further, the system may calculate a confidence score for thecomputerized privacy questionnaire based at least in part on theconfidence factor score for each of the one or more responses to one ormore questions in the computerized privacy questionnaire. Uponcalculating the confidence score, the system can use the confidencescore to determine whether user abnormal behavior occurred in providingthe one or more responses. In some implementations, a low confidencefactor score for a single response may cause the confidence score of theprivacy questionnaire to automatically indicate user abnormal behavioroccurred in providing the privacy questionnaire. However, in otherembodiments, this is not the case. For example, if only two out oftwenty confidence factor scores are very low (i.e., indicate a higherlikelihood of user abnormal behavior in providing the particularresponse), the system may determine, based on the calculated confidencescore for the privacy questionnaire, that user abnormal behavior did notoccur in completing the privacy questionnaire.

Privacy Assessment Monitoring Module

In particular embodiments, a Privacy Assessment Monitoring Module 2000is configured to: (1) monitor user inputs when the user is providinginformation related to a privacy campaign or completing a privacy impactassessment; and (2) determine, based at least in part on the userinputs, whether the user has provided one or more abnormal inputs orresponses. In various embodiments, the Privacy Assessment MonitoringModule 300 is configured to determine whether the user is, or may be,attempting to provide incomplete, false, or misleading information orresponses related to the creation of a particular privacy campaign, aprivacy impact assessment associated with a particular privacy campaign,etc.

Turning to FIG. 20, in particular embodiments, when executing thePrivacy Assessment Monitoring Module 2000, the system begins, at Step2010, by receiving an indication that a user is submitting one or moreresponses to one or more questions related to a particular privacycampaign. In various embodiments, the system is configured to receivethe indication in response to a user initiating a new privacy campaign(e.g., on behalf of a particular organization, sub-group within theorganization, or other suitable business unit). In other embodiments,the system is configured to receive the indication while a particularuser is completing a privacy impact assessment for a particular privacycampaign, where the privacy impact assessment provides oversight intovarious aspects of the particular privacy campaign such as, for example:(1) what personal data is collected as part of the privacy campaign; (2)where the personal data is stored; (3) who has access to the storedpersonal data; (4) for what purpose the personal data is collected, etc.

In various embodiments, the system is configured to receive theindication in response to determining that a user has accessed a privacycampaign initiation system (e.g., or other privacy system) and isproviding one or more pieces of information related to a particularprivacy campaign. In particular embodiments, the system is configured toreceive the indication in response to the provision, by the user, of oneor more responses as part of a privacy impact assessment. In variousembodiments, the system is configured to receive the indication inresponse to any suitable stimulus in any situation in which a user mayprovide one or more potentially abnormal responses to one or morequestions related to the collection, storage or use of personal data.

In various embodiments, the privacy campaign may be associated with anelectronic record (e.g., or any suitable data structure) comprisingprivacy campaign data. In particular embodiments, the privacy campaigndata comprises a description of the privacy campaign, one or more typesof personal data related to the campaign, a subject from which thepersonal data is collected as part of the privacy campaign, a storagelocation of the personal data (e.g., including a physical location ofphysical memory on which the personal data is stored), one or moreaccess permissions associated with the personal data, and/or any othersuitable data associated with the privacy campaign. In variousembodiments, the privacy campaign data is provided by a user of thesystem.

An exemplary privacy campaign, project, or other activity may include,for example: (1) a new IT system for storing and accessing personal data(e.g., include new hardware and/or software that makes up the new ITsystem; (2) a data sharing initiative where two or more organizationsseek to pool or link one or more sets of personal data; (3) a proposalto identify people in a particular group or demographic and initiate acourse of action; (4) using existing data for a new and unexpected ormore intrusive purpose; and/or (5) one or more new databases whichconsolidate information held by separate parts of the organization. Instill other embodiments, the particular privacy campaign, project orother activity may include any other privacy campaign, project, or otheractivity discussed herein, or any other suitable privacy campaign,project, or activity.

During a privacy impact assessment for a particular privacy campaign, aprivacy impact assessment system may ask one or more users (e.g., one ormore individuals associated with the particular organization orsub-group that is undertaking the privacy campaign) a series of privacyimpact assessment questions regarding the particular privacy campaignand then store the answers to these questions in the system's memory, orin memory of another system, such as a third-party computer server.

Such privacy impact assessment questions may include questionsregarding, for example: (1) what type of data is to be collected as partof the campaign; (2) who the data is to be collected from; (3) where thedata is to be stored; (4) who will have access to the data; (5) how longthe data will be kept before being deleted from the system's memory orarchived; and/or (6) any other relevant information regarding thecampaign. In various embodiments a privacy impact assessment system maydetermine a relative risk or potential issues with a particular privacycampaign as it related to the collection and storage of personal data.For example, the system may be configured to identify a privacy campaignas being “High” risk, “Medium” risk, or “Low” risk based at least inpart on answers submitted to the questions listed above. For example, aPrivacy Impact Assessment that revealed that credit card numbers wouldbe stored without encryption for a privacy campaign would likely causethe system to determine that the privacy campaign was high risk.

As may be understood in light of this disclosure, a particularorganization may implement operational policies and processes thatstrive to comply with industry best practices and legal requirements inthe handling of personal data. In various embodiments, the operationalpolicies and processes may include performing privacy impact assessments(e.g., such as those described above) by the organization and/or one ormore sub-groups within the organization. In particular embodiments, oneor more individuals responsible for completing a privacy impactassessment or providing privacy campaign data for a particular privacycampaign may attempt to provide abnormal, misleading, or otherwiseincorrect information as part of the privacy impact assessment. In suchembodiments, the system may be configured to receive the indication inresponse to receiving an indication that a user has initiated or isperforming a privacy impact assessment.

Returning to Step 2020, the system is configured to, in response toreceiving the indication at Step 310, monitor (e.g., actively monitor)the user's system inputs. In particular embodiments, actively monitoringthe user's system inputs may include, for example, monitoring,recording, tracking, and/or otherwise taking account of the user'ssystem inputs. These system inputs may include, for example: (1) one ormore mouse inputs; (2) one or more keyboard (e.g., text) inputs); (3)one or more touch inputs; and/or (4) any other suitable inputs (e.g.,such as one or more vocal inputs, etc.). In various embodiments, thesystem is configured to actively monitor the user's system inputs, forexample: (1) while the user is viewing one or more graphical userinterfaces for providing information regarding or responses to questionsregarding one or more privacy campaigns; (2) while the user is loggedinto a privacy portal; and/or (3) in any other suitable situationrelated to the user providing information related to the collection orstorage of personal data (e.g., in the context of a privacy campaign).In other embodiments, the system is configured to monitor one or morebiometric indicators associated with the user such as, for example,heart rate, pupil dilation, perspiration rate, etc.

In particular embodiments, the system is configured to monitor a user'sinputs, for example, by substantially automatically tracking a locationof the user's mouse pointer with respect to one or more selectableobjects on a display screen of a computing device. In particularembodiments, the one or more selectable objects are one or moreselectable objects (e.g., indicia) that make up part of a particularprivacy impact assessment, privacy campaign initiation system, etc. Instill other embodiments, the system is configured to monitor a user'sselection of any of the one or more selectable objects, which mayinclude, for example, an initial selection of one or more selectableobjects that the user subsequently changes to selection of a differentone of the one or more selectable objects.

In any embodiment described herein, the system may be configured tomonitor one or more keyboard inputs (e.g., text inputs) by the user thatmay include, for example, one or more keyboard inputs that the userenters or one or more keyboard inputs that the user enters but deleteswithout submitting. For example, a user may type an entry relating tothe creation of a new privacy campaign in response to a prompt that askswhat reason a particular piece of personal data is being collected for.The user may, for example, initially begin typing a first response, butdelete the first response and enter a second response that the userultimately submits. In various embodiments of the system describedherein, the system is configured to monitor the un-submitted firstresponse in addition to the submitted second response.

In still other embodiments, the system is configured to monitor a user'slack of input. For example, a user may mouse over a particular inputindicia (e.g., a selection from a drop-down menu, a radio button orother selectable indicia) without selecting the selection or indicia. Inparticular embodiments, the system is configured to monitor such inputs.As may be understood in light of this disclosure, a user that mousesover a particular selection and lingers over the selection withoutactually selecting it may be contemplating whether to: (1) provide amisleading response; (2) avoid providing a response that they likelyshould provide in order to avoid additional follow up questions; and/or(3) etc.

In other embodiments, the system is configured to monitor any othersuitable input by the user. In various embodiments, this may include,for example: (1) monitoring one or more changes to an input by a user;(2) monitoring one or more inputs that the user later removes ordeletes; (3) monitoring an amount of time that the user spends providinga particular input; and/or (4) monitoring or otherwise tracking anyother suitable information related to the user's response to aparticular question and/or provision of a particular input to thesystem.

Retuning to Step 2030, the system is configured to store, in memory, arecord of the user's submitted and un-submitted system inputs. Asdiscussed above, the system may be configured to actively monitor bothsubmitted and un-submitted inputs by the user. In particularembodiments, the system is configured to store a record of those inputsin computer memory (e.g., in the One or More Databases 140 shown in FIG.1). In particular embodiments, storing the user's submitted andun-submitted system inputs may include, for example, storing a recordof: (1) each system input made by the user; (2) an amount of time spentby the user in making each particular input; (3) one or more changes toone or more inputs made by the user; (4) an amount of time spent by theuser to complete a particular form or particular series of questionsprior to submission; and/or (5) any other suitable information relatedto the user's inputs as they may relate to the provision of informationrelated to one or more privacy campaigns.

Continuing to Step 2040, the system is configured to analyze the user'ssubmitted and un-submitted inputs to determine one or more changes tothe user's inputs prior to submission. In particular embodiments, thesystem may, for example: (1) compare a first text input with a secondtext input to determine one or more differences, where the first textinput is an unsubmitted input and the second text input is a submittedinput; (2) determine one or more changes in selection, by the user, of auser-selectable input indicia (e.g., including a number of times theuser changed a selection); and/or (3) compare any other system inputs bythe user to determine one or more changes to the user's responses to oneor more questions prior to submission. In various embodiments, thesystem is configured to determine whether the one or more changesinclude one or more changes that alter a meaning of the submitted andunsubmitted inputs.

In various embodiments, the system is configured to compare first,unsubmitted text input with second, submitted text input to determinewhether the content of the second text input differs from the first textinput in a meaningful way. For example, a user may modify the wording oftheir text input without substantially modifying the meaning of theinput (e.g., to correct spelling, utilize one or more synonyms, correctpunctuation, etc.). In this example, the system may determine that theuser has not made meaningful changes to their provided input.

In another example, the system may determine that the user has changedthe first input to the second input where the second input has a meaningthat differs from a meaning of the first input. For example, the firstand second text inputs may: (1) list one or more different individuals;(2) list one or more different storage locations; (3) include one ormore words with opposing meanings (e.g., positive vs. negative, shortvs. long, store vs. delete, etc.); and/or (4) include any otherdiffering text that may indicate that the responses provided (e.g., thefirst text input and the second text input) do not have essentially thesame meaning. In this example, the system may determine that the userhas made one or more changes to the user's inputs prior to submission.

Returning to Step 2050, the system continues by determining, based atleast in part on the user's system inputs and the one or more changes tothe user's inputs, whether the user has provided one or more abnormalresponses to the one or more questions. In various embodiments, thesystem is configured to determine whether the user has provided one ormore abnormal responses to the one or more questions based ondetermining, at Step 2040, that the user has made one or more changes toa response prior to submitting the response (e.g., where the one or morechanges alter a meaning of the response).

In other embodiments, the system is configured to determine that theuser has provided one or more abnormal responses based on determiningthat the user took longer than a particular amount of time to provide aparticular response. For example, the system may determine that the userhas provided an abnormal response in response to the user taking longerthan a particular amount of time (e.g., longer than thirty seconds,longer than one minute, longer than two minutes, etc.) to answer asimple multiple choice question (e.g., “Will the privacy campaigncollect personal data for customers or employees?”).

In particular embodiments, the system is configured to determine thatthe user has provided one or more abnormal responses based on a numberof times that the user has changed a response to a particular question.For example, the system may determine a number of different selectionsmade by the user when selecting one or more choices from a drop downmenu prior to ultimately submitting a response. In another example, thesystem may determine a number of times the user changed their free-formtext entry response to a particular question. In various embodiments,the system is configured to determine that the user provided one or moreabnormal responses in response to determining that the user changedtheir response to a particular question more than a threshold number oftimes (e.g., one time, two times, three times, four times, five times,etc.).

In still other embodiments, the system is configured to determine thatthe user has provided one or more abnormal responses based at least inpart on whether a particular question (e.g., threshold question) is a“critical” question. In particular embodiments, a critical question mayinclude a question that, if answered in a certain way, would cause thesystem's conditional logic trigger to present the user with one or morefollow-up questions. For example, the system may, in response toreceiving the user's full set of answers to the threshold questions,automatically identify any individual question within the series ofthreshold questions that, if answered in a particular way (e.g.,differently than the user answered the question) would have caused thesystem to display one or more follow up questions.

In various embodiments, the system is configured, for any questions thatare deemed “critical” (e.g., either by the system, or manually) todetermine whether the user exhibited any abnormal behavior whenanswering the question. For example, the system may check to see whetherthe user changed their answer once, or multiple times, before submittingtheir answer to the question (e.g., by tracking the user's keystrokes orother system inputs while they are answering the threshold question, asdescribed above). As another example, the system may determine whetherit took the user longer than a pre-determined threshold amount of time(e.g., 5 minutes, 3 minutes, etc.) to answer the critical thresholdquestion.

In particular embodiments, the system is configured to determine whetherthe user provided one or more abnormal responses based on any suitablecombination of factors described herein including, for example: (1) oneor more changes to a particular response; (2) a number of changes to aparticular response; (3) an amount of time it took to provide theparticular response; (4) whether the response is a response to acritical question; and/or (5) any other suitable factor.

Continuing to Step 2060, the system, in response to determining that theuser has provided one or more abnormal responses, automatically flagsthe one or more questions in memory. In particular embodiments, thesystem is configured to automatically flag the one or more questions inmemory by associating the one or more questions in memory with a listingor index of flagged questions. In other embodiments, the system, inresponse to flagging the one or more questions, is further configured togenerate a notification and transmit the notification to any suitableindividual. For example, the system may transmit a notification that oneor more question have been flagged by a particular privacy officer orother individual responsible ensuring that a particular organization'scollection and storage of personal data meets one or more legal orindustry standards.

In particular embodiments, the system is configured to generate a reportof flagged questions related to a particular privacy campaign. Invarious embodiments, flagging the one or more questions is configured toinitiate a follow up by a designated individual or team (e.g., a memberof the organization's privacy team) regarding the one or more questions.In particular embodiments, the system may also, or alternatively, beadapted to automatically generate and transmit a message to one or moreindividuals (e.g., the organization's chief privacy officer) indicatingthat the threshold question may have been answered incorrectly and thatfollow-up regarding the question may be advisable. After receiving themessage, the individual may, in particular embodiments, follow up withthe individual who answered the question, or conduct other additionalresearch, to determine whether the question was answered accurately.

Privacy Assessment Modification Module

In particular embodiments, a Privacy Assessment Modification Module 2100is configured to modify a questionnaire to include at least oneadditional question in response to determining that a user has providedone or more abnormal inputs or responses regarding a particular privacycampaign. For example, the system may, as discussed above, prompt theuser to answer one or more follow up questions in response todetermining that the user gave an abnormal response to a criticalquestion. In particular embodiments, modifying the questionnaire toinclude one or more additional questions may prompt the user to providemore accurate responses which may, for example, limit a likelihood thata particular privacy campaign may run afoul of legal or industry-imposedrestrictions on the collection and storage of personal data.

Turning to FIG. 21, in particular embodiments, when executing thePrivacy Assessment Modification Module 2100, the system begins, at Step2110, by receiving an indication that a user has provided one or moreabnormal inputs or responses to one or more questions during acomputerized privacy assessment questionnaire. In particularembodiments, the system is configured to receive the indication inresponse to determining that the user has provided one or more abnormalresponses to one or more questions as part of Step 2050 of the PrivacyAssessment Monitoring Module 2000 described above.

Continuing to Step 2120, in response to receiving the indication, thesystem is configured to flag the one or more questions and modify thequestionnaire to include at least one additional question based at leastin part on the one or more questions. In various embodiments, the systemis configured to modify the questionnaire to include at least one followup question that relates to the one or more questions for which the userprovided one or more abnormal responses. For example, the system maymodify the questionnaire to include one or more follow up questions thatthe system would have prompted the user to answer if the user hadsubmitted a response that the user had initially provided but notsubmitted. For example, a user may have initially provided a responsethat social security numbers would be collected as part of a privacycampaign but deleted that response prior to submitting what sort ofpersonal data would be collected. The system may, in response todetermining that the user had provided an abnormal response to thatquestion, modify the questionnaire to include one or more additionalquestions related to why social security numbers would need to becollected (or to double check that they, in fact, would not be).

In other embodiments, the system is configured to take any othersuitable action in response to determining that a user has provided oneor more abnormal responses. The system may, for example: (1)automatically modify a privacy campaign; (2) flag a privacy campaign forreview by one or more third party regulators; and/or (3) perform anyother suitable action.

Automated Vendor Risk Compliance Assessment Systems and Related Methods

In particularly embodiments, a vendor risk scanning system is configuredto scan one or more webpages associated with a particular vendor (e.g.,provider of particular software, particular entity, etc.) in order toidentify one or more vendor attributes. In particular embodiments, thesystem may be configured to scan the one or more web pages to identifyone or more vendor attributes such as, for example: (1) one or moresecurity certifications that the vendor does or does not have (e.g., ISO27001, SOC II Type 2, etc.); (2) one or more awards and/or recognitionsthat the vendor has received (e.g., one or more security awards); (3)one or more security policies and/or 3rd party vendor parties; (4) oneor more privacy policies and/or cookie policies for the one or morewebpages; (5) one or more key partners or potential sub processors ofone or more services associated with the vendor; and/or (6) any othersuitable vendor attribute. Other suitable vendor attributes may include,for example, membership in a Privacy Shield, use of StandardizedInformation Gathering (SIG), etc.

In various embodiments, the system is configured to scan the one or morewebpages by: (1) scanning one or more pieces of computer code associatedwith the one or more webpages (e.g., HTML, Java, etc.); (2) scanning oneor more contents of the one or more webpages (e.g., using one or morenatural language processing techniques); (3) scanning for one or moreparticular images on the one or more webpages (e.g., one or more imagesthat indicate membership in a particular organization, receipt of aparticular award etc.; and/or (4) using any other suitable scanningtechnique. The system may, for example, identify one or more image hostsof one or more images identified on the website, analyze the contents ofa particular identified privacy or cookie policy that is displayed onthe one or more webpages, etc. The system may, for example, beconfigured to automatically detect the one or more vendor attributesdescribed above.

In various embodiments, the system may, for example: (1) analyze the oneor more vendor attributes; and (2) calculate a risk rating for thevendor based at least in part on the one or more vendor attributes. Inparticular embodiments, the system is configured to automatically assigna suitable weighting factor to each of the one or more vendor attributeswhen calculating the risk rating. In particular embodiments, the systemis configured to analyze one or more pieces of the vendor's publishedapplications of software available to one or more customers for downloadvia the one or more webpages to detect one or more privacy disclaimersassociated with the published applications. The system may then, forexample, be configured to use one or more text matching techniques todetermine whether the one or more privacy disclaimers contain one ormore pieces of language required by one or more prevailing industry orlegal requirements related to data privacy. The system may, for example,be configured to assign a relatively low risk score to a vendor whosesoftware (e.g., and/or webpages) includes required privacy disclaimers,and configured to assign a relatively high risk score to a vendor whoseone or more webpages do not include such disclaimers.

In another example, the system may be configured to analyze one or morewebsites associated with a particular vendor for one or more privacynotices, one or more blog posts, one or more preference centers, and/orone or more control centers. The system may, for example, calculate thevendor risk score based at least in part on a presence of one or moresuitable privacy notices, one or more contents of one or more blog postson the vendor site (e.g., whether the vendor sire has one or more blogposts directed toward user privacy), a presence of one or morepreference or control centers that enable visitors to the site to opt inor out of certain data collection policies (e.g., cookie policies,etc.), etc.

In particular other embodiments, the system may be configured todetermine whether the particular vendor holds one or more securitycertifications. The one or more security certifications may include, forexample: (1) system and organization control (SOC); (2) InternationalOrganization for Standardization (ISO); (3) Health Insurance Portabilityand Accountability ACT (HIPPA); (4) etc. In various embodiments, thesystem is configured to access one or more public databases of securitycertifications to determine whether the particular vendor holds anyparticular certification. The system may then determine the privacyawareness score based on whether the vendor holds one or more securitycertifications (e.g., the system may calculate a relatively higher scoredepending on one or more particular security certifications held by thevendor). The system may be further configured to scan a vendor websitefor an indication of the one or more security certifications. The systemmay, for example, be configured to identify one or more images indicatedreceipt of the one or more security certifications, etc.

In still other embodiments, the system is configured to analyze one ormore social networking sites (e.g., Linkedln, Facebook, etc.) and/or oneor more business related job sites (e.g., one or more job-posting sites,one or more corporate websites, etc.) or other third-party websites thatare associated with the vendor (e.g., but not maintained by the vendor).The system may, for example, use social networking and other data toidentify one or more employee titles of the vendor, one or more jobroles for one or more employees of the vendor, one or more job postingsfor the vendor, etc. The system may then analyze the one or more jobtitles, postings, listings, roles, etc. to determine whether the vendorhas or is seeking one or more employees that have a role associated withdata privacy or other privacy concerns. In this way, the system maydetermine whether the vendor is particularly focused on privacy or otherrelated activities. The system may then calculate a privacy awarenessscore and/or risk rating based on such a determination (e.g., a vendorthat has one or more employees whose roles or titles are related toprivacy may receive a relatively higher privacy awareness score).

In particular embodiments, the system may be configured to calculate theprivacy awareness score using one or more additional factors such as,for example: (1) public information associated with one or more eventsthat the vendor is attending; (2) public information associated with oneor more conferences that the vendor has participated in or is planningto participate in; (3) etc. In some embodiments, the system maycalculate a privacy awareness score based at least in part on one ormore government relationships with the vendor. For example, the systemmay be configured to calculate a relatively high privacy awareness scorefor a vendor that has one or more contracts with one or more governmententities (e.g., because an existence of such a contract may indicatethat the vendor has passed one or more vetting requirements imposed bythe one or more government entities).

In any embodiment described herein, the system may be configured toassign, identify, and/or determine a weighting factor for each of aplurality of factors used to determine a risk rating score for aparticular vendor. For example, when calculating the rating, the systemmay assign a first weighting factor to whether the vendor has one ormore suitable privacy notices posted on the vendor website, a secondweighting factor to whether the vendor has one or more particularsecurity certifications, etc. The system may, for example, assign one ormore weighting factors using any suitable technique described hereinwith relation to risk rating determination. In some embodiments, thesystem may be configured to receive the one or more weighting factors(e.g., from a user). In other embodiments, the system may be configuredto determine the one or more weighting factors based at least in part ona type of the factor.

In any embodiment described herein, the system may be configured todetermine an overall risk rating for a particular vendor (e.g.,particular piece of vendor software) based in part on the privacyawareness score. In other embodiments, the system may be configured todetermine an overall risk rating for a particular vendor based on theprivacy awareness rating in combination with one or more additionalfactors (e.g., one or more additional risk factors described herein). Inany such embodiment, the system may assign one or more weighting factorsor relative risk ratings to each of the privacy awareness score andother risk factors when calculating an overall risk rating. The systemmay then be configured to provide the risk score for the vendor,software, and/or service for use in calculating a risk of undertaking aparticular processing activity that utilizes the vendor, software,and/or service (e.g., in any suitable manner described herein).

In a particular example, the system may be configured to identifywhether the vendor is part of a Privacy Shield arrangement. Inparticular, a privacy shield arrangement may facilitate monitoring of anentity's compliance with one or more commitments and enforcement ofthose commitments under the privacy shield. In particular, an entityentering a privacy shield arrangement may, for example: (1) be obligatedto publicly commit to robust protection of any personal data that ithandles; (2) be required to establish a clear set of safeguards andtransparency mechanisms on who can access the personal data it handles;and/or (3) be required to establish a redress right to addresscomplaints about improper access to the personal data.

In a particular example of a privacy shield, a privacy shield betweenthe United States and Europe may involve, for example: (1) establishmentof responsibility by the U.S. Department of Commerce to monitor anentity's compliance (e.g., a company's compliance) with its commitmentsunder the privacy shield; and (2) establishment of responsibility of theFederal Trade Commission having enforcement authority over thecommitments. In a further example, the U.S. Department of Commerce maydesignate an ombudsman to hear complaints from Europeans regarding U.S.surveillance that affects personal data of Europeans.

In some embodiments, the one or more regulations may include aregulation that allows data transfer to a country or entity thatparticipates in a safe harbor and/or privacy shield as discussed herein.The system may, for example, be configured to automatically identify atransfer that is subject to a privacy shield and/or safe harbor as ‘lowrisk.’ In this example, U.S. Privacy Shield members may be maintained ina database of privacy shield members (e.g., on one or more particularwebpages such as at www.privacysheild.gov). The system may be configuredto scan such webpages to identify whether the vendor is part of theprivacy shield.

In particular embodiments, the system may be configured to monitor theone or more websites (e.g., one or more webpages) to identify one ormore changes to the one or more vendor attributes. For example, a vendormay update a privacy policy for the website (e.g., to comply with one ormore legal or policy changes). In some embodiments, a change in aprivacy policy may modify a relationship between a website and itsusers. In such embodiments, the system may be configured to: (1)determine that a particular website has changed its privacy policy; and(2) perform a new scan of the website in response to determining thechange. The system may, for example, scan a website's privacy policy ata first time and a second time to determine whether a change hasoccurred. The system may be configured to analyze the change in privacypolicy to determine whether to modify the calculated risk rating for thevendor (e.g., based on the change).

The system may, for example, be configured to continuously monitor forone or more changes. In other embodiments, the system may be configuredto scan for one or more changes according to a particular schedule(e.g., hourly, daily, weekly, or any other suitable schedule.). Forexample, the system may be configured to scan the one or more webpageson an ongoing basis to determine whether the one or more vendorattributes have changed (e.g., if the vendor did not renew its PrivacyShield membership, lost its ISO certification, etc.).

In particular embodiments, any entity (e.g., organization, company,etc.) that collects, stores, processes, or otherwise handles personaldata (e.g., on behalf of its customers, employees, or other suitabledata subjects) may be subject to various privacy and security policies(e.g., such as the European Union's General Data Protection Regulation(GDPR), the California Consumer Privacy Act (CCPA), Nevada Senate Bill220 (SB-220), and other such policies) that relate to the handling ofsuch personal data. An entity may, for example, be required to bothcomply with one or more legal or industry standards related to thecollection and/or storage of private information (e.g., such as personaldata or personal information) and demonstrate such compliance. One ormore systems described herein may be configured to at least partiallyautomate such compliance (e.g., and at least partially automate one ormore activities that would support a demonstration of such compliancethrough use of the one or more systems).

In addition to personal data that an entity (e.g., or otherorganization) may collect, store, and/or process on its own behalf, anentity may utilize (e.g., contract with) data obtained from and/orcollected by one or more third-party vendors that also collect, store,and/or process personal data from one or more data subjects. Thesethird-party vendors may further rely on one or more sub-processors toprovide, collect, store, etc. data that those third-party vendors use,and so on. An entity may have agreements and/or contracts (e.g., writtenagreements) with each third-party vendor that set out the obligations ofeach party, including obligations to take certain actions in response toprivacy-related occurrences, such as a data breach or incident that mayaffect one or both of the parties. Similarly, third-party vendors mayhave agreements and/or contracts (e.g., written agreements) withsub-processors that set out the obligations of the third-part vendor anda sub-processor.

Under prevailing legal and industry standards related to the processingof personal data, an entity may be found to be in violation of one ormore laws or regulations if the entity utilizes a vendor (e.g., and/orsuch a vendor utilizes a sub-processor) that mishandles personal data.Accordingly, as may be understood in light of this disclosure, an entitymay desire to thoroughly vet (e.g., using one or more risk analysistechniques and/or vendor scoring techniques, such as any suitabletechnique described herein) any third-party vendors and/orsub-processors: (1) with which the entity contracts; (2) from which theentity receives personal data; (3) that store personal data on behalf ofthe entity; and/or (4) that otherwise collect, store, process, and/orhandle personal data on behalf of the entity, or in association with anyactivity undertaken by the vendor or sub-processor on behalf of, or forthe benefit of, the entity.

Third-party vendors that provide software applications and systems thathandle or access the personal data of others may, for example, providesuch software to large numbers of different customers (e.g., hundreds orthousands of different customers). This may add an additional level ofcomplexity to complying with one or more prevailing legal or industrystandards related to the handling of personal data, because an entitymay be required to ensure that any vendor that the entity utilizes isalso in compliance with such policies and regulations. As part ofensuring compliance with such regulations, an entity may conduct one ormore privacy audits (e.g., of activities undertaken by the entity, ofvendors utilized by and/or contracted with the entity, etc.).

Various embodiments of a vendor risk management system described hereinmay be configured to automate one or more processes related to the riskassessment, scoring, and/or analysis of particular vendors with which anentity may contract (e.g., new vendors that the entity would like tostart working with—e.g., by entering into a new contract, or existingvendors that the entity would like to continue working with—e.g., byrenewing an existing contract), or whose services an entity may utilizeas part of one or more business and/or data processing activities.Various embodiments may also be configured for use in assessing the riskassociated with one or more vendors before an entity pays the vendor.Further various embodiments of a vendor risk management system describedherein may be configured to determine obligations between an entity anda third-party vendor and/or a sub-processor and perform tasks (e.g.,automatically) to comply with such obligations. Particular embodimentsof a vendor risk management system are described more fully below.

Exemplary Technical Platforms

As will be appreciated by one skilled in the relevant field, the presentinvention may be, for example, embodied as a computer system, a method,or a computer program product. Accordingly, various embodiments may takethe form of an entirely hardware embodiment, an entirely softwareembodiment, or an embodiment combining software and hardware aspects.Furthermore, particular embodiments may take the form of a computerprogram product stored on a computer-readable storage medium havingcomputer-readable instructions (e.g., software) embodied in the storagemedium. Various embodiments may take the form of web-implementedcomputer software. Any suitable computer-readable storage medium may beutilized including, for example, hard disks, compact disks, DVDs,optical storage devices, and/or magnetic storage devices.

Various embodiments are described below with reference to block diagramsand flowchart illustrations of methods, apparatuses (e.g., systems), andcomputer program products. It should be understood that each block ofthe block diagrams and flowchart illustrations, and combinations ofblocks in the block diagrams and flowchart illustrations, respectively,can be implemented by a computer executing computer programinstructions. These computer program instructions may be loaded onto ageneral-purpose computer, special purpose computer, or otherprogrammable data processing apparatus to produce a machine, such thatthe instructions which execute on the computer or other programmabledata processing apparatus to create means for implementing the functionsspecified in the flowchart block or blocks.

These computer program instructions may also be stored in acomputer-readable memory that can direct a computer or otherprogrammable data processing apparatus to function in a particularmanner such that the instructions stored in the computer-readable memoryproduce an article of manufacture that is configured for implementingthe function specified in the flowchart block or blocks. The computerprogram instructions may also be loaded onto a computer or otherprogrammable data processing apparatus to cause a series of operationalsteps to be performed on the computer or other programmable apparatus toproduce a computer implemented process such that the instructions thatexecute on the computer or other programmable apparatus provide stepsfor implementing the functions specified in the flowchart block orblocks.

Accordingly, blocks of the block diagrams and flowchart illustrationssupport combinations of mechanisms for performing the specifiedfunctions, combinations of steps for performing the specified functions,and program instructions for performing the specified functions. Itshould also be understood that each block of the block diagrams andflowchart illustrations, and combinations of blocks in the blockdiagrams and flowchart illustrations, can be implemented by specialpurpose hardware-based computer systems that perform the specifiedfunctions or steps, or combinations of special purpose hardware andother hardware executing appropriate computer instructions.

Example System Architecture

FIG. 22 is a block diagram of a Vendor Risk Management System 2200according to a particular embodiment. In some embodiments, the VendorRisk Management System 2200 is configured to scan one or more websitesassociated with a particular vendor to identify and analyze one or moresecurity certifications, privacy and/or cookie policies, etc. The systemmay, for example, initiate a virtual browsing session on any of the oneor more servers and/or computers described below in order to facilitatethe scanning of the one or more webpages (e.g., in order to access andthen scan the one or more websites).

As may be understood from FIG. 22, the Vendor Risk Management System2200 includes one or more computer networks 2215, a Vendor Risk ScanningServer 2210, a Vendor Risk Analysis Server 2220 (e.g., which may beconfigured to analyze data identified during a scan of the vendor'swebsite(s)), One or More Third Party Servers 2260, one or more databases2240 (e.g., which may be used to store data used as part of theanalysis, results of the analysis, etc.), and one or more remotecomputing devices 2250 (e.g., a desktop computer, laptop computer,tablet computer, etc.). In particular embodiments, the one or morecomputer networks 2215 facilitate communication between the Vendor RiskScanning Server 2210, a Vendor Risk Analysis Server 2220, One or MoreThird Party Servers 2260, one or more databases 2240, and one or moreremote computing devices 2250. The Vendor Risk Analysis Server 2220, theVendor Risk Management System 2200, or a vendor risk management serverdescribed herein may be configured to perform any of the functions andprocesses set forth herein.

The one or more computer networks 2215 may include any of a variety oftypes of wired or wireless computer networks such as the Internet, aprivate intranet, a public switch telephone network (PSTN), or any othertype of network. The communication link between Vendor Risk ScanningServer 2210 and Vendor Risk Analysis Server 2220 may be, for example,implemented via a Local Area Network (LAN) or via the Internet.

Vendor Management Overview

In particular embodiments, any entity (e.g., organization, company,etc.) that collects, stores, processes, or otherwise handles personaldata (e.g., on behalf of its customers, employees, or other suitabledata subjects) may be subject to various privacy and security policies(such as the European Union's General Data Protection Regulation (GDPR),the California Consumer Privacy Act (CCPA), Nevada Senate Bill 220(SB-220), and other such policies) that relate to the handling of suchpersonal data. An entity may, for example, be required to both complywith one or more legal or industry standards related to the collectionand/or storage of private information (e.g., such as personal data orpersonal information) and demonstrate such compliance. One aspect ofsuch compliance may be disclosing data breaches to one or moreregulating parties, such as one or more supervisory authorities. One ormore systems described herein may be configured to at least partiallyautomate such compliance (e.g., and at least partially automate one ormore activities that would support a demonstration of such compliancethrough the use of the one or more systems).

In addition to personal data that an entity (e.g., a company or otherorganization) may collect, store, and/or process on its own behalf, anentity may utilize data obtained from and/or collected by one or morethird-party vendors that also collect, store, and/or process personaldata from one or more data subjects. These third-party vendors mayfurther rely on one or more sub-processors to provide, collect, process,and/or store data that those third-party vendors use, and so on.

Within the context of such business relationships, it is common for anentity to have contractual obligations to disclose privacy-relatedoccurrences, such as a data breach or other privacy or security-relatedincident, to its business partners. For example, an entity may have oneor more verbal or written agreements (e.g., contracts) in place witheach of the entity's third-party vendors that set out the obligations ofeach party, including one or more obligations to take certain actions inresponse to specified privacy-related occurrences, such as a datasecurity-related incident that may affect any of the parties to theagreement. Similarly, third-party vendors may have respective agreementsand/or contracts (e.g., written agreements) with sub-processors that setout respective privacy-related obligations of the third-party vendor andone or more of its sub-processors. One or more systems described hereinmay be configured to at least partially facilitate and/or automate suchcompliance with such contractual obligations.

It is noted that under prevailing legal and industry standards relatedto the processing of personal data, an entity may be found to be inviolation of one or more laws or regulations if the entity utilizes avendor (e.g., and/or such a vendor utilizes a sub-processor) thatmishandles personal data. Accordingly, as may be understood in light ofthis disclosure, an entity may desire to thoroughly vet (e.g., using oneor more risk analysis techniques and/or vendor scoring techniques, suchas any suitable technique described herein) any third-party vendorsand/or sub-processors: (1) with which the entity contracts; (2) fromwhich the entity receives personal data; (3) that store personal data onbehalf of the entity; and/or (4) that otherwise collect, store, process,and/or handle personal data on behalf of the entity, or in associationwith any activity undertaken by the vendor or sub-processor on behalfof, or for the benefit of, the entity.

Third-party vendors that provide software applications and/or systemsthat handle and/or access the personal data of others may, for example,provide such software to large numbers of different customers (e.g.,hundreds or thousands of different customers). This may add anadditional level of complexity to complying with one or more prevailinglegal or industry standards related to the handling of personal data,because an entity may be required to ensure that any vendor that theentity utilizes is also in compliance with such policies andregulations. As part of ensuring compliance with such regulations, anentity may conduct one or more privacy audits (e.g., of activitiesundertaken by the entity, of vendors utilized by and/or contracted withthe entity, etc.).

Various embodiments of a vendor risk management system described hereinmay be configured to automate one or more processes related to the riskassessment, scoring, and/or analysis of particular vendors with which anentity may contract, or whose services an entity may utilize as part ofone or more business and/or data processing activities. Further variousembodiments of vendor risk management systems described herein may beconfigured to determine obligations between an entity and a third-partyvendor and/or a sub-processor and perform tasks (e.g., automatically) tocomply with such obligations. Particular embodiments of a vendor riskmanagement system are described more fully below.

Vendor Incident Management

In various embodiments, the system may be configured to automaticallyfacilitate a response to one or more incidents (e.g., security-relatedincidents, privacy-related incidents, data breaches, etc.). Inparticular, the system may be configured to: (1) identify a particularincident; (2) determine a method by which the incident was reported(e.g., via webform); (3) identify a country of origin of the incident;(4) generate one or more tasks related to the incident (e.g., one ormore reporting tasks and/or notification tasks that should be completedin order to properly respond to the identified incident); (5)communicate the one or more tasks to one or more users; and/or (6) takeany other suitable action related to the breach.

The system may, for example, be configured to generate one or more tasksbased at least in part on one or more contractual and/or legalobligations of the entity (e.g., with respect to one or more otherentities, such as one or more vendors of the entity). For example, thesystem may determine that, based at least in part on one or morecontract terms derived, for example, using one or more techniquesdescribed herein, the entity is obligated to notify a particular vendor,regulator, sub-processor, or other entity within a specified timeframeof any material data breach. The system may, at least partially inresponse to identifying such a data breach, be configured to generate atask to notify one or more particular vendors, regulators, and/or otherentities (e.g., within the prescribed timeframe). The system maydetermine such contract terms, for example, by using one or more naturallanguage processing techniques to analyze the text of one or morerelevant contracts, such as one or more relevant contracts between anentity and a third-party vendor. The system may be configured to receiveany such contracts and agreements as uploaded documents for analysis(e.g., for use by the system in determining, from the documents, one ormore key terms, obligations, penalties, etc. that the entity and/or oneor more third parties, such as one or more of the entity's vendors aresubject to in regard to disclosing, for example, one or more specifiedtypes of relevant privacy-related events, such as a data breach).

In various embodiments, the system is configured to automate thesubmission of notifications of one or more data breaches and/or otherprivacy-related incidents to one or more entities for which acontractual obligation to notify exists (e.g., a vendor). In particularembodiments, the system is configured to determine one or moreattributes of a security-related incident in order to determine whetheran obligation to a vendor has arisen, and, if so, what responsiveactions should be performed. For example, the system may be configuredto determine attributes such as: (1) a geographical region or country inwhich the incident occurred; (2) a scope of the security-relatedincident; (3) a date and time of occurrence of the security-relatedincident; (4) one or more systems, assets, processes, vendors, etc. thatwere affected by the security-related incident; and/or (5) one or moreapplicable regulatory or legal schemes.

The system may further be configured to analyze a security-relatedincident using such attributes to determine additional information. Forexample, the system may analyze security-related incident attributes todetermine a risk level of the security-related incident. The system maythen use such determined attributes and optionally additionalinformation to determine the obligations implicated by thesecurity-related incident (e.g., to a particular vendor). Based on suchdetermined obligations, the system may generate one or more tasks (e.g.,automatically) to be performed to satisfy the entity's obligationsassociated with the security-related incident. In various embodiments,the system may recommend a remediation for determined risks in responsethe security-related incident with respect to one or more contractualcommitments or privacy regulations. In various embodiments, the systemmay perform such tasks, for example, automatically, or upon receipt ofan instruction from a user (e.g., received via an activation of acontrol on a graphical user interface).

The system may, for example, be configured to: (1) capture, investigate,and/or analyze the risk, liability, and/or obligations of an entitystemming from a security-related incident such as a data breach; (2)parse one or more contracts to identify one or more notificationobligations and/or regulatory/jurisdictional obligations to determineone or more required and/or desirable subsequent actions based on a typeof incident and/or one or more details about the incident; (3) identifyone or more assets, vendors, processes, etc. that are affected by theincident (e.g., based on one or more identified contractualobligations); (4) capture the scope of the incident (e.g., use a mobileapplication to take a picture relevant to the incident, scan an assettag of a computing device involved in the incident, etc.); and/or (5)maintain a master database of privacy-related incidents (e.g., based oncase law, incident reports, etc.) in order to determine a risk level ofa particular incident; etc.

FIG. 23 shows an example process that may be performed by an IncidentNotification Module 2300. In executing the Incident Notification Module2300, the system begins at Step 2310, where it receives an indication ofa security-related incident. The system may automatically receive thisindication, for example, in response to the creation and/or detection,by the system, of an incident report. In various embodiments, suchincident reports may be generated, for example: (1) by a user throughuse of a graphical user interface provided by the system; and/or (2)automatically by a breach detection and/or reporting system, which maybe part of the present system.

At Step 2320, the system may determine one or more attributes of theindicated security-related incident. Such attributes may be providedwhen the incident report was created, for example by a user via agraphical user interface, or as determined by an automated incidentreport generation system. Such attributes may be stored in or otherwiseassociated with a record of the incident in the system's memory.Attributes can be any type of information associated with asecurity-related incident, including, but not limited to (1) ageographical region or country in which the incident occurred; (2) ascope of the incident; (3) a date and time of occurrence of theincident; (4) one or more affected systems, assets, processes, vendors,etc.; and/or (5) one or more controlling regulatory or legal schemes.

At Step 2330, based on the information available about thesecurity-related incident (e.g., attributes as determined at Step 2320),the system may determine additional information for the security-relatedincident. For example, the system may determine a risk level and/orregulatory regime for an incident based, at least in part, on thelocation and/or scope of the incident and/or the affected systems. Thesystem may determine any other additional information associated withthe incident using any available resources at Step 2330.

At Step 2340, the system may determine one or more third-party entities(e.g., third party vendors) that may be involved and/or associated withthe security-related incident using one or more of the attributes of thesecurity-related incident and/or any additional information determinedfor the security-related incident. For example, the system maydetermine, in some embodiments based at least in part on one or moreattributes of a particular data breach, that the data breach hasaffected one or more email systems in Germany. The system may thendetermine that the applicable email systems in Germany are hosted by oneor more particular vendors. Accordingly, the system may conclude thatthe one or more particular vendors have been affected by the databreach.

The system may next, at Step 2350, analyze one or more contracts withthe one or more determined entities (e.g., as determined at Step 2340)to determine whether one or more notification obligations to suchentities exist and, if so, the particular requirements of suchobligations. For example, the system may determine that a particularvendor contract includes an obligation of an entity to alert theparticular vendor of any data breach affecting a particular serviceinvolving that vendor within 48 hours of the entity learning of the databreach. It should be understood that notification obligations mayspecify, for example, any particular requirements related to therequired notification, such as the form of the notification (e.g.,email, phone call, letter, etc.), timeframe of the notification (24hours, 48 hours, five business days, etc.), information to be includedin the notification, etc. The system may be configured to analyze suchcontracts using natural language processing techniques to scan thelanguage of the contracts in order to determine the particularobligations and associated requirements.

Based on the determined obligations, at Step 2360 the system maygenerate one or more tasks that should be performed to satisfy suchobligations. The system may then present such tasks to a user forcompletion, for example, in a suitable graphical user interface on adisplay screen associated with the system. The system may present one ormore such tasks to the user along with any related information, asdescribed in more detail herein. The system may also, or instead,automatically perform one or more of such tasks and may notify a user ofthe system's automatic performance and/or completion of such tasks, forexample, via a suitable user interface.

Vendor Risk Scanning and Scoring Systems

A vendor risk management system may be configured to perform any one ormore of several functions related to managing vendors and/or otherthird-party entities. In various embodiments, a vendor management systemmay be a centralized system providing the functions of vendor compliancedemonstration, vendor compliance verification, vendor scoring (e.g.,vendor risk rating, vendor privacy compliance scoring, etc.), and/orvendor information collection. The system may use various sources ofinformation to facilitate vendor-related functions, such as, but notlimited to: (1) publicly available vendor information (e.g., fromwebsites, regulator bodies, industry associations, etc.); (2)non-publicly available information (e.g., private information,contracts, etc.); and/or (3) internally-generated information (e.g.,internally-generated scoring information, internally-generated rankinginformation, one or more internally-maintained records of interactionswith the vendor, one or more internal records of privacy-relatedincidents, etc.).

In particular embodiments, a vendor risk management system may beconfigured to scan one or more systems and/or publicly availableinformation associated with a particular vendor. The system may extractvendor information from such sources and/or use the extractedinformation to determine one or more vendor risk scores for theparticular vendor. The system may, for example, be configured to defineparticular scoring criteria for one or more privacy programs (e.g.,associated with a particular vendor of the entity) and use the scoringcriteria to determine one or more vendor risk scores for the particularvendor (e.g., a vendor or sub-processor that processes data on behalf ofthe entity) based on the particular scoring criteria. The system mayalso, or instead, be configured to define particular scoring criteriafor one or more privacy programs (e.g., associated with a particularvendor of the entity and/or a particular product or service of theparticular vendor) and use the scoring criteria to determine respectiverisk scores for one or more products (services, offerings, etc.)provided by the particular vendor based on the particular scoringcriteria. In various embodiments, suitable scoring criteria may be basedon any suitable vendor information (e.g., any suitable informationassociated with the vendor), including, but not limited to, publiclyavailable information and non-publicly available information.

Suitable vendor information may include, for example: (1) one or moresecurity certifications that the vendor may or may not have (e.g., ISO27001, SOC II Type 2, etc.); (2) one or more awards and/or recognitionsthat the vendor has received (e.g., one or more security awards); (3)one or more security policies the vendor may have in place, (4) one ormore third parties (e.g., sub-processors, third-party vendors, etc.)with which the vendor may do business or otherwise interact; (5) one ormore privacy policies and/or cookie policies for one or more vendorwebpages (e.g., one or more webpages associated with the vendor,operated by the vendor, etc.); (6) one or more partners and/or potentialsub-processors associated with one or more products offered by thevendor; (7) one or more typical vendor response times to one or moreparticular types of incidents; (8) one or more typical vendor responsetimes to one or more particular types of requests for information formthe vendor; (9) vendor financial information (e.g., publicly availablefinancial information for the vendor such as revenue, stock price,trends in stock price, etc.); (10) news related to the vendor (e.g., oneor more news articles, magazine articles, blog posts, etc.); (11) one ormore data breaches experienced by the vendor (e.g., one or moreannounced breaches) and/or the vendor's response to such breaches;and/or (12) any other suitable vendor information. Other suitable vendorinformation may include, for example, membership in a Privacy Shieldand/or participation in one or more treaties and/or organizationsrelated to a demonstration of meeting certain privacy standards, use ofStandardized Information Gathering (SIG), etc. Particular exemplaryvendor information is discussed more fully below.

In particular embodiments, the system may, for example, be configured toscan one or more webpages associated with a particular vendor (e.g., oneor more webpages operated by the particular vendor, one or more webpagesoperated on behalf of the particular vendor, one or more webpagescomprising information associated with the particular vendor, etc.) inorder to identify one or more pieces of vendor information that mayserve as a basis for calculating and/or otherwise determining one ormore vendor risk scores (e.g., one or more vendor compliance scores, oneor more vendor privacy risk scores, one or more vendor security riskscores, etc.). In various embodiments, the system may be configured toscan the one or more webpages by: (1) scanning one or more pieces ofcomputer code associated with the one or more webpages (e.g., HTML,Java, etc.); (2) scanning one or more contents (e.g., text content) ofthe one or more webpages (e.g., using one or more natural languageprocessing techniques); (3) scanning for one or more particular imageson the one or more webpages (e.g., one or more images that indicatemembership in a particular organization, receipt of a particular award,etc.); and/or (4) using any other suitable scanning technique to scanthe one or more webpages. When scanning a particular webpage or multiplewebpages, the system may, for example, perform one or more functionssuch as identifying one or more hosts of one or more images identifiedon the particular webpage or multiple webpages, analyzing the contentsof one or more particular identified privacy and/or cookie policies thatare displayed on the one or more webpages, identify one or moreparticular terms, policies, and/or other privacy-related languageincluded in the text of the particular webpage or multiple webpages,etc. The system may, for example, be configured to automatically detectany of the one or more pieces of vendor information described above. Thesystem may also, or instead, be configured to detect any of the one ormore pieces of vendor information at least partially in response to adetection and/or receipt of a user input, such as the selection of auser-selectable control (e.g., user-selectable indicia, webform button,webpage control, etc.) in a graphical user interface presented to auser. The system may also, or instead, be configured to initiatedetection of any of the one or more pieces of vendor information inresponse to any other type of input or condition.

In various embodiments, the system may, for example analyze the one ormore pieces of vendor information and calculate or otherwise determine arisk score for the vendor based at least in part on the one or morepieces of vendor information. The system may also use other informationin conjunction with the one or more pieces of vendor information tocalculate or otherwise determine a vendor risk score. In particularembodiments, the system is configured to automatically assign one ormore weighting factors to each of the one or more pieces of vendorinformation and/or to each of one or more pieces of other informationwhen calculating the risk score.

In particular embodiments, the system is configured to analyze one ormore pieces of a vendor's published software applications of softwareand/or documentation associated with vendor software (e.g., that may beavailable to one or more customers for download via one or morewebpages) to detect one or more privacy disclaimers associated with suchsoftware. The system may then, for example, be configured to use one ormore text matching techniques to determine whether the one or moreprivacy disclaimers contain one or more pieces of language required byone or more prevailing industry and/or legal standards and/orrequirements related to data privacy and/or security. The system may,for example, be configured to assign a relatively low risk score to avendor whose products (e.g., software, services, webpages, otherofferings, etc.) include one or more required privacy disclaimers.Likewise, the system may, for example, be configured to assign arelatively high risk score to a vendor whose products do not includesuch disclaimers.

In various embodiments, the system may be configured to analyze one ormore webpages associated with a particular vendor for one or moreprivacy notices, one or more blog posts, one or more preference centers,and/or one or more control centers. The system may then, for example,calculate a vendor privacy risk score based, at least in part, on apresence of one or more of: (1) one or more suitable privacy notices;(2) contents of one or more blog posts on one or more vendor sites(e.g., whether the vendor site has one or more blog posts directedtoward user privacy); (3) a presence of one or more preference centersand/or control centers that enable visitors to the site to opt-in oropt-out of certain data collection policies (e.g., cookie policies,etc.); and/or (4) any other security-related information,privacy-related information etc. that may be present on one or morewebpages associated with the particular vendor.

In particular embodiments, the system may be configured to determinewhether the particular vendor holds one or more certifications (e.g.,one or more security certifications, one or more privacy certifications,one or more industry certifications etc.) such as one or more system andorganization controls (SOC) or International Organization forStandardization (ISO) certifications or one or more certificationsrelated to Health Insurance Portability and Accountability ACT (HIPAA).In various embodiments, the system is configured to access one or morepublic databases of certifications to determine whether the particularvendor holds any particular certification. The system may then determinea risk score based, at least in part, on whether the vendor holds one ormore certifications (e.g., the system may calculate a relatively higherscore if the vendor holds one or more particular certifications). Thesystem may be further configured to scan a vendor website for anindication of one or more certifications. The system may, for example,be configured to identify one or more images that indicate receipt ofone or more certifications. In various embodiments, the system may beconfigured to calculate a vendor risk score based on one or morecertifications that the system determines that the vendor does or doesnot hold.

In a particular embodiment, the system may first scan one or more vendorwebsites for one or more indications that the vendor has one or morecertifications as discussed above. Next, in response to determining thatthe vendor has indicated that they have one or more certifications(e.g., via their website or otherwise), the system may be adapted toverify whether the vendor actually has the indicated one or moresecurity certifications by automatically confirming this with one ormore independent data sources, such as a public database of entitiesthat hold security certifications.

In still other embodiments, the system is configured to analyze one ormore social networking sites (e.g., LinkedIn, Facebook, etc.), one ormore business related job sites (e.g., one or more job-posting sites,one or more corporate websites, etc.), and/or one or more otherthird-party websites that may be associated with and/or containinformation pertaining to the vendor (e.g., that are not operated by, oron behalf of, the vendor). The system may, for example, use socialnetworking data (e.g., obtained from one or more social networkwebsites) and/or other data to identify one or more titles of employeesof the vendor, one or more job roles for one or more employees of thevendor, one or more job postings for the vendor, etc. The system maythen analyze the one or more job titles, postings, listings, roles, etc.to determine whether the vendor has and/or is seeking one or moreemployees that have a role associated with addressing data privacy, datasecurity, and/or other privacy or security concerns (e.g., a role thatrequires data privacy experience). In this way, the system may determinewhether the vendor is particularly focused on privacy, security, and/orother related activities. The system may then calculate a risk score forthe vendor based, at least in part, on such a determination (e.g., avendor that has one or more employees whose roles and/or titles arerelated to security may receive a relatively higher risk score ascompared to a vendor who does not).

In particular embodiments, the system may be configured to calculate therisk score using one or more additional factors such as, for example:(1) public information associated with one or more events that thevendor is attending; (2) public information associated with one or moreconferences that the vendor has participated in and/or is planning toparticipate in; (3) one or more publications and/or articles written byauthors associated with and/or sponsored by the vendor; (4) publicrelations material issued by the vendor, (5) one or more news articlesand/or reports about the vendor; and/or (6) any other public informationabout and/or associated with the vendor. In some embodiments, the systemmay calculate a risk score for the vendor based, at least in part, onone or more governmental relationships of the vendor (e.g.,relationships that the vendor has with one or more particular governmententities). For example, the system may be configured to calculate arelatively low risk score for a vendor that has one or more contractswith one or more government entities (e.g., because an existence of sucha contract may indicate that the vendor has passed one or more vettingrequirements imposed by the one or more government entities).

In particular embodiments, the system may be configured to determine avendor risk score based, at least in part, on one or more pieces ofinformation contained in one or more documents that define arelationship between the vendor and the entity (e.g., one or morecontracts, one or more agreements, one or more licenses, etc.). Thesystem may be configured to receive one or more such documents asuploaded documents, for example, provided via a suitable user interface.For example, for one or more such documents, the system may beconfigured to: (1) receive a copy of a particular document; (2) scan theparticular document to identify particular language (e.g., one or moreparticular terms, clauses, etc.) contained in the document; (3)categorize the particular language based on one or more pre-defined termlanguage categories; and/or (4) modify and/or calculate a risk score forthe vendor based on the presence and/or absence of the particularlanguage.

In particular embodiments, the system may be configured to analyze(e.g., using natural language processing) one or more such documents toidentify key terms. The system may, for example, be automaticallyconfigured to identify one or more: (1) term limits; (2) breachnotification timeline obligations; (3) sub-processor change notificationrequirements; (4) liability caps/obligations; (5) data breach liabilityterms; (6) indemnification terms; (7) required data transfer mechanisms;(8) notification time periods for a data breach; (9) notificationrequirements for sub-processor changes; (10) terms requiring one or moresecurity certifications; (11) terms requiring compliance with one ormore regulatory regimes; and/or (12) any other privacy or securityrelated terms within the one or more documents.

In particular embodiments, as described herein, the system may beconfigured to generate one or more vendor risk assessment questionnairesand transmit the one or more questionnaires to a particular vendor forcompletion. The system may later receive the completed questionnaire anduse one or more pieces of vendor information (as obtained from thevendor's responses to the various questions within the questionnaire) incalculating the vendor risk score.

In various embodiments, the system may be configured to automaticallygenerate an expiration date for any particular piece of information usedin the determination of a vendor risk score (e.g., one or more pieces ofvendor information derived from a questionnaire and/or assessmentrelated to the vendor, determined from one or more webpage scans,identified in one or more uploaded documents, etc.). Such an expirationdate may, for example, be based on an explicit characteristic of thepiece of information, such as the date on which a security certificationexpires. Alternatively, or in addition, an expiration date may bedetermined based on one or more system configurations (e.g.,privacy-related data may be set to expire six months after the systemidentifies/determines the information, which may help ensure that thesystem maintains current information).

The system may use any other criteria to set information expirationdates. Any piece of information may have an expiration date that may bedistinct and/or independent from the expiration date associated with anyother piece of information. Alternatively, or in addition, a piece ofinformation may have an expiration date tied to and/or associated withan expiration date of another piece of information.

In various embodiments, the system may be configured for, in response todetermining that a particular piece of vendor-related information usedby the system has expired, automatically requesting and/or attempting toobtain an updated version of the expired information. In variousembodiments, automatically requesting and/or obtaining updatedinformation may comprise, for example: (1) generating an updated riskassessment questionnaire for completion by the vendor and facilitatingcompletion of the questionnaire by the vendor; (2) competing an updatedscan of one or more pieces of publicly available information associatedwith the vendor; (3) completing an updated scan of one or more vendorsystems; (4) analyzing one or more new versions of one or moreparticular vendor documents; and/or (5) performing other suitableactivities to obtain updated information, etc. In particularembodiments, the system may then be configured to calculate an updatedvendor risk score based, at least in part, on one or more pieces of theupdated information. In any embodiment described herein, the system maybe configured to determine whether the one or more pieces of updatedinformation are sufficient to demonstrate continued compliance, by thevendor, with one or more obligations under one or more privacy laws,standards and/or regulations, one or more obligations under one or morevendor contracts, etc.

In any embodiment described herein, the system may be configured toassign, identify, and/or determine a weighting factor for each of aplurality of factors used to determine a risk score for a particularvendor. For example, when calculating a risk score for a particularvendor, the system may assign a first weighting factor to whether thevendor has one or more suitable privacy notices posted on a websiteassociated with the vendor, a second weighting factor to whether thevendor has one or more particular security certifications, etc. Thesystem may, for example, assign one or more weighting factors using anysuitable technique described herein with relation to risk ratingdetermination. In various embodiments, the system may be configured toreceive the one or more weighting factors (e.g., from a user). Invarious embodiments, the system may also, or instead, be configured todetermine the one or more weighting factors based at least in part on atype of the factor.

In any embodiment described herein, the system may be configured todetermine an overall risk score for a particular vendor (e.g.,applicable to all pieces of the vendor's software) based at least inpart on a risk score associated with a subset of the vendor's products.In various embodiments, the system may be configured to determine anoverall risk score for a particular vendor based at least in part on arisk score associated with a subset of the vendor's products incombination with one or more additional factors (e.g., one or moreadditional risk factors described herein). In various embodiments, thesystem may be configured to determine an overall risk rating for aproduct of a particular vendor based, at least on part, on a risk scoreassociated with one or more of the vendor's other products incombination with one or more additional factors (e.g., one or moreadditional risk factors described herein). In various embodiments, thesystem may assign one or more weighting factors to each of one or morerisk scores and/or other risk factors that may be used when calculatingan overall risk score. The system may then be configured to provide arisk score (e.g., an overall risk score) for the vendor and/or a vendorproduct for use in calculating a risk of undertaking a particularprocessing activity that utilizes the vendor and/or a particular productof the vendor (e.g., in any suitable manner described herein).

In a particular example, the system may be configured to determinewhether the vendor is part of a Privacy Shield arrangement. In variousembodiments, a privacy shield arrangement may facilitate monitoring of avendor's compliance with one or more commitments and may facilitateenforcement of those commitments under the privacy shield. Inparticular, a vendor entering a privacy shield arrangement may, forexample: (1) be obligated to publicly commit to robust protection of anypersonal data that it handles; (2) be required to establish a clear setof safeguards and transparency mechanisms regarding who can access thepersonal data the vendor handles; and/or (3) be required to establish aredress right to address complaints about improper access to thepersonal data. The system may then be configured to use thedeterminization of the vendor's participation and/or membership in aprivacy shield and/or one or more similar arrangement to determine arisk score for that vendor.

In a particular example of a privacy shield arrangement between theUnited States and Europe, the U.S. Department of Commerce may beresponsible for monitoring a vendor's compliance (e.g., a company'scompliance) with its commitments under the privacy shield and theFederal Trade Commission may be responsible for enforcement authorityover such commitments. In a further example, the U.S. Department ofCommerce may designate an ombudsman to hear complaints from Europeansregarding U.S. surveillance that affects personal data of Europeans.

In various embodiments, regulations related to data privacy and/or datasecurity may include one or more regulations that allow data transfer toa country or entity that participates in a safe harbor and/or a privacyshield as discussed herein. The system may, for example, be configuredto automatically identify a transfer that is subject to a privacy shieldand/or safe harbor as “low risk.” For example, U.S. Privacy Shieldmembers may be maintained in a database of privacy shield members (e.g.,on one or more particular webpages such as www.privacyshield.gov). Thesystem may be configured to scan one or more webpages reflectinginformation stored in such databases to determine whether the vendor ispart of the privacy shield and/or to otherwise obtain informationassociated with the vendor.

In particular embodiments, the system may be configured to monitor theone or more web sites (e.g., one or more webpages) and/or other systemsto identify one or more changes to one or more pieces of vendorinformation. For example, a vendor may update a privacy policy for oneof its websites (e.g., to comply with one or more legal or policychanges). In various embodiments, a change in a privacy policy maymodify a relationship between a website and its users. In particularembodiments, the system may be configured to determine that a particularwebsite has changed its privacy policy and responsively perform a newscan of the web site to obtain updated privacy-related information forthe vendor. The system may, for example, scan a website's privacy policyat a first time and at a second, later time and compare such scans todetermine whether a change has occurred. The system may be configured toperform scanning of websites and/or other sources of vendor informationroutinely and/or automatically. The system may be configured to analyzeany changes (e.g., a change in a privacy policy for the vendor posted ona particular web page of the web site) to determine whether and how tomodify a calculated risk score for a vendor (e.g., based on the change).

The system may, for example, be configured to continuously monitor aparticular web site and/or web page for one or more changes. In variousembodiments, the system may be configured to scan for one or morechanges according to a particular schedule (e.g., hourly, daily, weekly,or any other suitable schedule.). For example, the system may beconfigured to scan one or more webpages and/or other sources of vendorinformation on an ongoing basis to determine whether any pieces ofvendor information have changed (e.g., whether the vendor has notrenewed its Privacy Shield membership, lost its ISO certification,etc.).

FIG. 24 shows an example process that may be performed by a VendorCompliance Demonstration Module 2400. In executing the Vendor ComplianceDemonstration Module 2400, the system begins at Step 2410, where itdetermines vendor information. The Vendor Compliance DemonstrationModule 2400 may determine vendor information based on a selection of acontrol on a graphical user interface, such as a control or indicia onan interface associated with a vendor. In various embodiments, theVendor Compliance Demonstration Module 2400 may determine vendorinformation from user input such as text input on a graphical userinterface, for example, when a user inputs information for a new vendorto be analyzed for compliance as described herein. In variousembodiments, the Vendor Compliance Demonstration Module 2400 maydetermine vendor information using information (e.g., a vendor name)received from a user and/or associated with an interface activity (e.g.,selection of a control) to query a database of vendor information.

At Step 2410, determining vendor information may include performinganalysis on one or more documents to determine the vendor information.For example, the system may be configured to retrieve one or morecontracts that an entity has entered into with a vendor from a databaseusing a vendor's name. The system may then analyze such one or morecontracts (e.g., using natural language processing) to identify one ormore particular terms used in the one or more contract that may beuseful in calculating a vendor risk score for the vendor. The system maybe configured to also, or instead, obtain and/or determine any otherinternally sourced data associated with the vendor at Step 2410, such asinternal records of interactions with the vendor, business relationshipinformation for the vendor, service provided by the vendor, length ofrelationship with vendor, expiration of vendor service agreements, etc.

At Step 2420, the system may obtain publicly available vendorinformation. In doing so, the system may be configured to scan one ormore webpages operated by or on behalf of the vendor and performanalysis of such webpages to determine, for example, any of the variousfactors related to privacy and/or security described herein. The systemmay also be configured to scan one or more webpages that are notoperated by, or on behalf of, the vendor and perform analysis of suchsites to determine any of the various factors related to privacy and/orsecurity described herein. For example, the system may scan and analyzewebsites of one or more privacy certification organizations and/orindustry groups to extract one or more factors related to privacy and/orsecurity associated with the vendor. The system may perform suchanalysis using natural language processing and/or metadata analysis toextract data from one or more websites and/or other sources ofinformation.

The system may also verify one or more factors at Step 2420. Forexample, the system may determine that a vendor's webpage indicates thatthe vendor holds a particular privacy certification and may then analyzethe webpage of the organization that issues the particular privacycertification to verify that the vendor does indeed hold the claimedprivacy certification or to determine that the vendor does not hold theprivacy certification as claimed. At Step 2420, the system may accessand/or analyze information from one or more other publicly availablesources of information, such as databases, publications, libraries, etc.

At Step 2430, the system may calculate a vendor risk score, as describedin more detail herein. In various embodiments, this calculation may beperformed based at least in part on the vendor information determined atStep 2410 and/or the publicly available information obtained at Step2420. In determining the vendor's risk score, the system may use any oneor more factors, each of which may be weighted according to any criteriaas described herein.

At Step 2440, the system may use any of the vendor information (e.g., asdetermined at Step 2410), publicly available vendor information (e.g.,as determined at Step 2420), and/or a calculated vendor risk score(e.g., as determined at Step 2430) to determine any additional vendorinformation. For example, the system may calculate a supplemental scorefor the vendor (e.g., based at least in part on the score determined atStep 2430 in combination with another score associated with theparticular vendor). Such a supplemental score may relate to any one ormore security attributes of the particular vendor, one or more privacyattributes of the particular vendor, and/or one or more privacy orsecurity attributes of one or more products provided by the particularvendor.

In various examples, the system may perform analysis of vendorinformation, publicly available vendor information, and/or one or morevendor risk scores at Step 2440 to determine the additional information.For example, the system may analyze one or more news reports retrievedat Step 2420 to identify a data breach involving the particular vendorand determine, as additional vendor information, that the breach was ahigh risk incident. In another example, the system may analyze thestatus of a privacy certification held by the particular vendor anddetermine that the certification expires within a short time period. Inresponse, as additional vendor information, the system may determine atStep 2440 (e.g., based on one or more additional pieces of information)that the particular vendor is at high risk of losing the privacycertification. In another example, the system may analyze a number ofand/or one or more descriptions of privacy-related officers in theparticular vendor's organization (e.g., their respective job titlesand/or backgrounds) and determine, as additional vendor information,that the particular vendor treats privacy issues as a high priority, andtherefore has lower relative privacy risk as opposed to otherorganizations. In yet another example, the system may determine one ormore additional scores and/or rankings beyond a vendor risk scorereflecting calculations based on other criteria at Step 2440, such as acompliance score reflecting the particular vendor's compliance with aparticular privacy standard and/or regulatory regime. The system may useany information available for the particular vendor to determine anyadditional vendor information.

At Step 2450, the system may generate a graphical user interface andpresent, to a user, all or any subset of the vendor information, thepublicly-available vendor information, the vendor privacy risk score,and/or the additional vendor information.

As noted herein, each piece of information associated with a vendor,regardless of how obtained or used by the presently disclosed systems,may have an associated expiration date. FIG. 25 shows an example processthat may be performed by a Vendor Information Update Module 2500 thatmay utilize such expiration dates. In executing the Vendor InformationUpdate Module 2500, the system begins at Step 2510, where it determinesa piece of vendor information. This may be suitable any piece of vendorinformation, such as, but not limited to, a piece of non-publiclyavailable vendor information , a piece of publicly available vendorinformation, a vendor risk score, and/or a piece of additional vendorinformation (e.g., as described herein). Such a piece of vendorinformation may be retrieved from a database and/or otherwise obtainedusing any suitable means.

At Step 2520, an expiration date associated with the retrieved piece ofvendor information may be evaluated and determined to have passed. Thisexpiration date may have been set based on an intrinsic characteristicof the piece of information (e.g., a date of expiration of privacycertification) and/or on one or more criteria associated with theacquisition, determination, and/or storage of the piece of information(e.g., six months after a date of acquisition, determination, and/orstorage of the piece of information).

At Step 2530, responsive to determining that the expiration date haspassed, the system may initiate a process to obtain and/or determine anupdated piece of information. For example, the system may generate andtransmit another assessment to the particular vendor associated with theexpired piece of information to acquire an updated corresponding pieceof information. In another example, the system may recalculate a riskscore for the particular vendor associated with an expired risk scoreusing current information. In another example, the system may scan oneor more webpages for updates in order to determine an updated piece ofinformation.

At Step 2540, the system may determine whether a valid updated piece ofvendor information was obtained (e.g., determined, received). If anupdated piece of information was successfully obtained (e.g., one ormore responses to an updated assessment sent to a vendor were received,an updated privacy risk score was calculated, updated information wasdetermined from analyzed webpages, etc.), at Step 2550 the system maystore this updated piece of information and a new expiration date,associating the updated piece of information and the new expiration datewith the appropriate vendor. Alternatively, if the system was unable toupdate an expired piece of information (e.g., no response was receivedto an updated assessment questionnaire sent to a vendor, an updatedprivacy risk score could not be calculated due to a lack of sufficientcurrent information, no updated information is currently available fromcurrent webpages, etc.), at Step 2560, the system may store anindication that the piece of information is expired, invalid, and/orotherwise should not be relied upon (e.g., store such an indication in adatabase and associate the indication with the piece of informationand/or the vendor).

FIG. 26 shows an example process that may be performed by a Vendor RiskScore Calculation Module 2600. In executing the Vendor Risk ScoreCalculation Module 2600, the system begins at Step 2610, where itdetermines and/or otherwise obtains non-publicly available vendorinformation (e.g., non-publicly available vendor information,information determined from one or more documents, etc.), publiclyavailable vendor information, and/or vendor assessment information(e.g., as described herein). Such information may be any information andcriteria as described herein.

At Step 2620, for each piece of non-publicly available vendorinformation, publicly available vendor information, and/or vendorassessment information, the system may be configured to determinewhether the piece of information is valid. In various embodiments, todetermine whether a piece of information is valid, the system maydetermine whether an expiration date associated with the piece ofinformation has passed. If the expiration date has passed (e.g., theinformation has expired), the system may be configured to requestupdated information corresponding to the expired piece of informationusing, for example, means described herein (e.g., one or more processessuch as those described in regard to FIG. 25). Other verificationcriteria may also, or instead, be used. For example, the system mayanalyze a piece of vendor information to determine whether it matchesknown information (e.g., a vendor name on a security certificationmatches a known vendor name, a vendor address on an industry membershiproll matches a known vendor address, a name of vendor representative ina particular position listed in a contract matches a known vendorrepresentative in that position, etc.). Any invalid information may beaddressed in any effective manner, such as those described herein.

At Step 2630, the system may determine a value for each piece ofnon-publicly available vendor information, publicly available vendorinformation, and/or vendor assessment information that is to be used incalculating a vendor risk score (e.g., a vendor privacy risk score, avendor security risk score, a vendor privacy risk rating, a vendorsecurity risk rating, etc.). For example, in order to calculate anumerical vendor risk score, the system may determine a numerical valuefor each piece of non-publicly available vendor information, publiclyavailable vendor information, and/or vendor assessment information. Thesystem may be configured to assign a numerical value to each respectivepiece of non-publicly available vendor information, publicly availablevendor information, and/or vendor assessment information using anycriteria, including those described herein and/or any other suitableprocess, algorithm, etc.

At Step 2640, the system may be configured to apply a weighting factorto each respective value determined for each respective piece ofnon-publicly available vendor information, publicly available vendorinformation, and/or vendor assessment information. In variousembodiments, some pieces of such information may be considered moreimportant in determining a vendor risk score than others. The system maybe configured to assign a greater weight to such information of elevatedimportance when calculating a vendor risk score. For example, a vendor'scurrent one or more security certifications may be considered to be ofgreater importance than a vendor's attendance at one or moreprivacy-related events. In such an example, the system may apply aweighting factor to the value associated with the vendor's securitycertifications that is greater than the weighting factor applied to thevalue associated with the vendor's attendance at privacy events. Variousmeans of determining suitable weighting factors may be used, includingas described herein.

At Step 2650, the system may calculate the vendor risk score using therespective weighted values of each piece of non-publicly availablevendor information, publicly available vendor information, and/or vendorassessment information. The system may, for example, be configured toperform a calculation to determine the score, such as averaging theweighted values of each piece of information. Alternatively, or inaddition, the system may be configured to employ more detailedcalculations and/or algorithms using the weighted values of each pieceof information to determine the vendor privacy risk score. At Step 2660,the system may generate a graphical user interface and present thevendor risk score to a user. In various embodiments, the system maypresent the vendor privacy risk score on a graphical user interface thatdisplays other information as well, including any interface describedherein.

In particular embodiments, the system may be configured to generate andmaintain a database of vendor information (e.g., including a riskanalysis for each of a plurality of particular vendors). Any informationassociated with a vendor in any way (e.g., any vendor-relatedinformation described herein) may be stored in and/or retrieved fromsuch a vendor information database. Such information may be acquiredand/or determined by the system via any means described herein (e.g.,scanning of webpages, analyzing vendor privacy risk assessments,analyzing contractual terms, analyzing one or more documents associatedwith the vendor, etc.). The system may provide access to, or provideinformation retrieved from, such a vendor information database toentities that may wish to contract with (e.g., in a new contract or byrenewing an existing contract), pay, or otherwise utilize or interactwith one or more vendors that are in the database. The system may alsoprovide access to, or provide information retrieved from, such a vendorinformation database to entities that already have an existingrelationship with one or more vendors that are in the database. In thisway, the system may enable such entities to assess the risk of, forexample, integrating new vendors into a new or existing processingactivity, a risk associated with paying the vendor, and/or the risk ofcontinuing a relationship with one or more vendors.

In various embodiments, vendor information (of any type) may beretrieved using one or more data models. A data model may be stored in avendor information database and/or in any other storage means availableto the disclosed systems. A data model may be associated with a vendorand may map one or more relationships between and/or among a pluralityof data assets utilized by a vendor (e.g., alone or in combination withanother entity). In particular embodiments, each of the plurality ofdata assets (e.g., data systems) may include, for example, any assetthat collects, processes, contains, and/or transfers data (e.g., such asa software application, “internet of things” computerized device,database, website, data-center, server, etc.). For example, a first dataasset may include any software or device (e.g., server or servers)utilized by a particular vendor for such data collection, processing,transfer, storage, etc. A data model may store any of the followinginformation: (1) the vendor that owns and/or uses a particular dataasset; (2) one or more departments within the vendor responsible for thedata asset; (3) one or more software applications that collect data(e.g., personal data) for storage in and/or use by the data asset (e.g.,or one or more other suitable collection assets from which the personaldata that is collected, processed, stored, etc. by the primary dataasset is sourced); (4) one or more particular data subjects and/orcategories of data subjects that information is collected from for useby the data asset; (5) one or more particular types of data that arecollected by each of the particular applications for storage in and/oruse by the data asset; (6) one or more individuals (e.g., particularindividuals or types of individuals) that are permitted to access and/oruse the data stored in, or used by, the data asset; (7) which particulartypes of data each of those individuals are allowed to access and use;and/or (8) one or more data assets (destination assets) that the data istransferred to for other use, and which particular data is transferredto each of those data assets. In particular embodiments, the data modelstores this information for each of a plurality of different data assetsand may include links between, for example, a portion of the model thatprovides information for a first particular data asset and a secondportion of the model that provides information for a second particulardata asset.

In various embodiments, vendor information (of any type) may beretrieved using one or more data maps (e.g., privacy-related data maps).A data map may include a visual and/or computer-readable representationof one or more data models that may include one or more data assets, oneor more connections between the one or more data assets, one or moreinventory attributes, one or more vendor attributes, etc. For example, adata map may include one or more of: (1) a visual or other indication ofa first data asset (e.g., a storage asset), a second data asset (e.g., acollection asset), and a third data asset (e.g., a transfer asset); (2)a visual or other indication of a flow of data (e.g., personal data)from the second data asset to the first data asset (e.g., from thecollection asset to the storage asset); (3) a visual or other indicationof a flow of data (e.g., personal data) from the first data asset to thethird data asset (e.g., from the storage asset to the transfer asset);(4) one or more visual or other indications of a risk level associatedwith the transfer of personal data; and/or (5) any other suitableinformation related to the one or more data assets, the transfer of databetween/among the one or more data assets, access to data stored orcollected by the one or more data assets, etc.

In particular embodiments, the data map identifies one or moreelectronic associations between at least two data assets within a datamodel comprising a respective digital inventory for each of the two ormore data assets, each respective digital inventory comprising one ormore respective inventory attributes selected from a group consistingof: (A) one or more processing activities associated with each of therespective data assets; (B) transfer data associated with each of therespective data assets; and (C) respective identifiers of one or morepieces of personal data associated with each of the respective dataassets.

The system may be configured to provide a user-accessible “dashboard”(e.g., a graphical user interface) through which a user (e.g., on behalfof an entity) may initiate a process of requesting information for avendor (a current or new vendor to the entity). The system may, forexample, perform a risk assessment (e.g., privacy risk assessment,security risk assessment, privacy impact assessment, etc.) for aspecified particular vendor, which may include: (1) determining whethera current risk assessment exists for the particular vendor within thesystem (e.g., whether a current risk assessment is stored within a datastructure (e.g., a database) associated with the system); (2)determining how long the particular vendor (e.g., a business entity) hasbeen in business; (3) identifying one or more privacy and/or securityrelated incidents (e.g., data breaches) associated with the particularvendor and/or one or more sub-processors utilized by the particularvendor; and/or (4) analyzing any other available data related to theparticular vendor. Based at least in part on the analyzed vendor data,the system may determine whether to: (1) automatically trigger a new orupdated risk assessment for the vendor; (2) automatically approve theparticular vendor (e.g., as a business partner for a particular entityand/or for involvement in a particular processing activity); and/or (3)automatically reject the particular vendor (e.g., as a business partnerfor a particular entity and/or for involvement in a particularprocessing activity).

For example, at least partially in response to determining that theparticular vendor has an existing, older vendor risk assessment storedwithin a database stored within a data structure associated with thesystem (e.g., a vendor risk assessment that is past a particular age,such as six months), the system may be configured to trigger a newvendor risk assessment for the particular vendor (e.g., using anysuitable technique described herein). In another example, the system maybe configured to trigger a new vendor risk assessment for the particularvendor in response to determining that the particular vendor hasexperienced one or more privacy-related incidents and/or asecurity-related incidents (e.g., a data breach) after the most recentvendor risk assessment was completed for the particular vendor. In yetanother example, the system may be configured to automatically approvethe particular vendor in response to determining that the systemcurrently stores a recent vendor risk assessment for the particularvendor, and/or that the particular vendor has had no recent privacyand/or security incidents. Any such approvals or rejections may also bebased, at least in part, on other information associated with theparticular vendor, including, but not limited to: (1) one or more vendorrisk scores; (2) one or more terms contained in one or more documents(e.g., contracts, licenses, agreements, etc.) involving the vendor; (3)one or more privacy and/or security certifications held by the vendor;(4) any other public information about the vendor (e.g., retrieved byscanning webpages or accessing databases); and/or (5) any other suitablevendor-related information, described herein or otherwise.

In particular embodiments, the system is configured to maintain adatabase of vendor privacy-specific information (e.g., scoring criteria)for use in such assessments. The system may be configured toperiodically (e.g., every month, every week, annually, every six months,or at any other suitable interval) update such privacy-specificinformation and/or to monitor for one or more changes to suchprivacy-specific information (e.g., vendor privacy information) andupdate the database in response to identifying any such changes. Anyinformation in such a database may have an associated expiration date,the passing of which may trigger the system to (e.g., substantiallyautomatically) attempt to obtain updated information for the vendor.

FIG. 27 shows an example process that may be performed by a Vendor RiskDetermination Module 2700. In executing the Vendor Risk DeterminationModule 2700, the system begins at Step 2710, where it receives a requestassess the risk associated with a particular vendor. The system mayreceive such a request via a graphical user interface where a user hasselected the vendor from a prepopulated listing or otherwise specifiedthe particular vendor for which information is desired (e.g., asdescribed herein).

At Step 2720, the system may attempt to retrieve any currently availableinformation for the particular vendor (e.g., a completed risk assessment(e.g., a privacy risk assessment, a security risk assessment, etc.) forthe vendor, a summary of such a risk assessment, and/or any othersuitable information regarding the vendor), for example, from a vendorinformation database.

At Step 2730, the system may determine whether a current risk assessmentwas retrieved from the vendor information database for the particularvendor. In various embodiments, if no current, valid vendor riskassessment for the vendor exists in the database (e.g., an existingassessment has expired, is invalid, or is not present), the system maybe configured to responsively obtain an updated (e.g., new) vendor riskassessment from the particular vendor at Step 2731 (e.g., as describedherein). At least partially in response to obtaining an updated vendorrisk assessment for the vendor and/or determining that a current, validvendor risk assessment was retrieved from the vendor informationdatabase, the system may proceed to Step 2740.

At Step 2740, the system may determine whether other vendor information(e.g., any vendor information described herein beyond a vendor riskassessment) retrieved from the vendor information database for theparticular vendor is present, current, and valid. In variousembodiments, if the system retrieves expired or otherwise invalid vendorinformation at this step, and/or any required vendor information is notpresent in the vendor information database, the system may be configuredto responsively obtain updated (e.g., new) information (e.g., using anymeans described herein) at Step 2741. At least partially in response toobtaining any needed vendor information and/or determining that allrequired vendor information retrieved from the vendor database iscurrent and valid, the system may proceed to Step 2750.

At Step 2750, the system may determine whether a current vendor riskscore retrieved from the vendor information database for the particularvendor is available to the system (e.g., saved to a database associatedwith the system) and current. If the system retrieves an expired vendorrisk score or there is no vendor risk score present in the vendorinformation database for the particular vendor, the system may beconfigured to responsively calculate an updated (e.g., new) vendor riskscore (e.g., using any means described herein) at Step 2751. At leastpartially in response to calculating an updated vendor risk score and/ordetermining that the vendor risk score retrieved from the vendordatabase is current, the system may proceed to Step 2760.

At Step 2760, the system may be configured to determine whether toapprove the use (e.g., new or continued) of the particular vendor basedat least in part on the information retrieved and/or otherwisedetermined previously (e.g., in prior steps). In various embodiments,any or all of the information described in regard to FIG. 27, orelsewhere herein, may be used, at least in part, by the system to makethis determination. If, at Step 2770, the system determines that theparticular vendor is approved for new or continued use with the entity,then, at Step 2771, the system may present an indication of suchapproval to a user. The system may present such an indication on agraphical user interface (or via any other suitable communicationsmechanism—e.g., a paper report, an audio signal, etc.) that may alsoinclude a presentation of any of the vendor information describedherein. If, at Step 2770, the system determines that the particularvendor is rejected from new or continued use with the entity, then, atStep 2772, the system may instead present an indication of suchrejection to a user. Here again, the system may present such anindication on a graphical user interface (or via any other suitablecommunications mechanism—e.g., a paper report, an audio signal, etc.)that may also include presentation of any of the vendor informationdescribed herein.

It should be understood that various alternative embodiments of thesystem may function differently than described above. For example, whilethe system is described above as using three different types ofinformation to determine whether to approve or reject a particularvendor, other embodiments may use only one or two of these three typesof information or may use different or other information when makingthis determination.

Dynamic Vendor Training Material Generation

In particular embodiments, the system may be configured to generatetraining material associated with a particular vendor based at least inpart on privacy information associated with that particular vendor, suchas the vendor's privacy risk score, any privacy-related information forthe vendor, any publicly available information for the vendor,sub-processors used by the vendor, privacy and/or security incidentsinvolving the vendor, etc. (e.g., any information described herein thatmay be associated with a vendor). In various embodiments, such trainingmaterial may be intended for use by an entity to train employees on howto evaluate, interact, and/or otherwise operate with the particularvendor with whom the training is associated. In various embodiments,such training material may be intended for use by the particular vendoritself, for example as training recommended and/or required by theentity engaging the particular vendor. Any other use of such trainingmaterial is contemplated in various embodiments.

The system may generate vendor-specific training material on-demand, forexample, at least partially in response to the detection of a selectionof a user-selectable control on a graphical user interface, where thecontrol is associated with requesting the generation of such material.

The system may also, or instead, generate vendor-specific trainingmaterial at least partially in response to detection of an occurrenceassociated with the particular vendor. For example, the system may beconfigured to detect (e.g., using any suitable technique describedherein) a change in any vendor information described herein (e.g., achange in a vendor risk score, a change in a vendor sub-processor, etc.)and/or detect an incident or other event involving the vendor (e.g., aprivacy breach, a security incident, etc.). In response to detection ofsuch an occurrence, the system may be configured to dynamically (e.g.,substantially automatically) update training material associated withthe involved vendor to reflect the detected occurrence. The system maybe configured to adjust existing training material in an appropriatemanner, update existing training material, and/or generate new trainingmaterial based at least in part on the occurrence. In variousembodiments, the generated training material may also include one ormore training assessments that may be used to gauge how well therecipients of the training material have absorbed the material. Thesystem may be configured to store training material in a vendor databaseas described herein or in any appropriate system.

FIG. 28 shows an example process that may be performed by a DynamicVendor Privacy Training Material Generation Module 2800. In executingthe Dynamic Vendor Privacy Training Generation Module 2800, the systembegins at Step 2810, where a request to generate vendor-related trainingmaybe received by the module. Such a request may be received via agraphical user interface where a user has selected the vendor from aprepopulated listing of vendors and/or otherwise specified theparticular vendor for which training is desired (e.g., as describedherein).

At Step 2820, the system may retrieve any currently availableinformation for the particular vendor, for example, from a vendorinformation database. This information may include any vendorinformation described herein (e.g., vendor privacy risk assessment,vendor risk score, vendor incident history, publicly available vendorinformation, etc.). This information may also include any other suitableinformation that may be of use in generating training materialassociated with a particular vendor, such as: (1) one or more trainingmaterial templates; (2) general information to be included in any vendortraining; (3) background on applicable privacy and/or security laws andregulations; (4) one or more standard procedures for interacting withvendors; and/or (5) any other generally applicable vendor trainingmaterial.

At Step 2830, the system may generate the training material associatedwith the particular vendor using any of the information obtained at Step2820. The generated training material may take any suitable form (e.g.,one or more manuals, slide decks, audio files, video files, etc.). AtStep 2840, the system may present an indication on a graphical userinterface that the training material associated with the particularvendor has been generated and/or may include a user-selectable controlon such an interface that allows a user to download or otherwise accesssuch training material. Such a graphical user interface may also includepresentation of any of the vendor information described herein. At Step2840, the system may also store the generated training material, forexample, in a vendor database as described herein and/or in anyappropriate system.

FIG. 29 shows an example process that may be performed by a DynamicVendor Privacy Training Material Update Module 2900. In executing theDynamic Vendor Privacy Training Material Update Module 2900, the systembegins at Step 2910, where the system may detect an occurrenceassociated with a particular vendor. For example, the system may detecta change in any vendor information and/or an incident involving thevendor (e.g., any information or occurrence as described herein).

At Step 2920, in response to detecting the change or occurrenceassociated with the particular vendor, the system may retrieve anyupdated information for the particular vendor (e.g., from a vendorinformation database) and/or any other information relevant to thedetected change or occurrence. This information may include anyinformation described herein. As with the process of FIG. 29, thisinformation may also include any other information that may be of use ingenerating training material associated with a particular vendor.

At Step 2930, the system may generate the training material associatedwith the particular vendor using any of the updated and/or occurrenceinformation obtained at Step 2920. At Step 2940, the system may presentan indication on a graphical user interface that the updated trainingmaterial associated with the particular vendor has been generated. Sucha graphical user interface may include a user-selectable control thatallows a user to download or otherwise access such updated trainingmaterial. Such a graphical user interface may also include presentationof any of the vendor information described herein. At Step 2940, thesystem may also store the generated training material in a vendordatabase as described herein or in any appropriate system.

It should be understood that various alternative embodiments of thesystem may function differently than described above. For example, whilethe system is described above as using three different types ofinformation to determine whether to approve or reject a particularvendor, other embodiments may use only one or two of these three typesof information or may use different or other information when makingthis determination.

Exemplary User Experience Exemplary Vendor Incident Management UserExperience

FIGS. 30-34 depict exemplary screen displays that a user may encounterwhen utilizing an exemplary system configured to provide notificationsof a security-related incident to one or more vendors of a particularentity. For example, a vendor list page 3010 illustrated in FIG. 30presents a listing of vendors and associated vendor attributes (e.g.,vendor name, service products provided by each respective vendor, vendorscore (which may, for example, indicate a privacy rating and/or securityrating for the vendor), criticality of each respective vendor to theparticular entity, associated business unit for each respective vendor(e.g., that the entity does direct business with), privacy impactassessment status for each respective vendor, status of each respectivevendor with respect to the entity, etc.). The vendor list page 3010 maybe represented in a graphical user interface, or in any other suitableformat.

At least partially in response to an occurrence and/or detection of anincident, the system may generate and/or present an incident alert 3020on the vendor list page 3010. Incident alert 3020 may include a summaryand/or brief description of the incident and may be, or include, auser-selectable object that instructs the system to generate an incidentdetail page, such as incident detail page 3110 of FIG. 31.

Turning now to FIG. 31, at least partially in response to an occurrenceand/or detection, by the system, of an incident and/or in response toselection of a control requesting incident details, the system maygenerate a page presenting the details of a security-related incident,such as incident detail page 3110. The incident detail page 3110 may berepresented in a graphical user interface, such as a webpage.

The incident detail page 3110 may include various attributes 3120 of asecurity-related incident. For example, as may be understood from FIG.31, incident detail page 3110 may display: (1) the method used to reportthe incident; (2) a date that the incident was reported (e.g.,05/12/18); (3) a geographical location of occurrence of the incident(e.g., USA); and/or (4) a description of the incident. Additionalinformation may also be presented, such as potentially impactedprocessing activities and/or contracts 3130 (e.g., processing activitiesand/or contracts that may be affected by the particular incident). Thesystem may receive additional information, such as the potentiallyimpacted processing activities and/or contracts 3130, when receivinginformation about the incident and/or the system may determine suchadditional information based on information received about the incidentand/or one or more attributes of the incident (e.g., attributes 3120)and/or the system's analysis of such information and/or attributes.

As noted herein, at least partially in response to receiving and/oranalyzing incident information and/or one or more attributes of theincident, the system may determine one or more vendors associated withthe incident and/or the notification obligations for each such vendor.

Turning now to FIG. 32, the system may generate a page presenting thedetails of a security-related incident and associated vendornotification tasks, such as incident detail page 3210. The incidentdetail page 3210 may be presented in a graphical user interface. Similarto the incident detail page 3110, the incident detail page 3210 mayinclude various attributes 3220 of security-related incident. Forexample, as seen on the incident detail page 3210, a method of reportingthe incident may be presented (e.g., web form), as well as a datereported (e.g., 05/12/18), a geographical location of occurrence of theincident (e.g., USA), and a description of the incident.

The system may also include, on incident detail page 3210, a listing oftasks 3230 to be performed to satisfy one or more of the entity'sincident notification obligations to the vendor. As noted herein, thesystem may determine one or more affected vendors and associatedobligations, and any information associated therewith, by analyzing oneor more vendor contracts and/or one or more attributes of the incident.The listing of tasks 3230 may include a title for each respective task(e.g., “Notify Amazon Web Services”), a status for each respective task(e.g., “New”), a timeframe for completion of each respective task (e.g.,“48 Hrs”), whether each respective task is required (e.g., “Yes”), auser to whom each respective task is assigned (e.g., “UserName Here”),and/or a deadline for completion of each respective task (e.g.,“4/25/2018”).

One or more sections of each task listing presented in listing of tasks3230 may be user selectable. At least partially in response toactivating (e.g., “hovering” or moving a cursor onto) such a section,the system may generate a pop-up window 3240 providing a briefdescription of the task to be performed. In response to clicking on, orotherwise selecting, a task from the listing of tasks 3230, the systemmay generate a task details page, such as the task detail page 3310 ofFIG. 33.

Turning now to FIG. 33, the system may generate a page presenting thedetails of a vendor notification task, such as task detail page 3310.The task detail page 3310 may include a reason section 3320 that mayprovide a brief explanation for why this vendor incident notificationtask should be performed. A detailed explanation section 3330 mayprovide additional information, such as one or more excerpts from theapplicable contract, agreement, regulation, law, etc. A task informationsection 3340 may list the task to be performed and any responses thatmay have been received to the task received (e.g., from the vendor, fromthose asked to perform the task, etc.). A user may provide anyadditional information associated with the task by uploading one or morefiles to the system in upload section 3350. For example, thecommunication (e.g., email, letter, documentation of a phone call) usedto satisfy the task may be uploaded or otherwise recorded here. Uponcompletion of the task, the task may be marked as complete by a user atcompletion control 3360. Any other changes to the task, such as statuschange, indication of actions taken, partial completion of the task,changes made to the task details, etc., may be saved by the user (e.g.,via task detail page 3310). The system may store any such task detailsand changes, including an indication of satisfaction of a vendorincident notification task, in a suitable database or elsewhere.

The system may provide a summary of incidents that includes one or moreincidents associated with one or more vendors for ease of evaluation.Turning now to FIG. 34, the system may generate a page, such as incidentsummary page 3410, presenting a listing of incident-related tasks,including vendor notification tasks. The incident summary page 3410 mayinclude an incident summary listing 3420 that may include a listing oftasks (e.g., to be performed, in progress, and/or completed). The tasklisting 3420 may indicate a type of each respective task (e.g., “DataLeak”, “Vendor Incident”), a severity of each respective task (e.g.,“Very High”, “Medium”), a status of each respective task (e.g.,“Notify—New”, “Complete”), a contact person for each respective task(e.g., “Steve”, “Carrie”), and a date of creation of each respectivetask (e.g., “12/20/17”, 11/15/17”, “10/20/17”).

Exemplary Vendor Risk Scanning and Scoring Experience

FIGS. 35-46 depict exemplary screen displays that a user may encounterwhen utilizing any suitable system described herein to view and/ordetermine a vendor's compliance, privacy, and/or security scoring and/orother attributes. These exemplary screen displays may also, or instead,be encountered by a user when onboarding a new vendor on behalf of anentity utilizing any suitable system described herein. For example,these exemplary screen displays may be encountered by a user associatedwith an entity in evaluating a vendor according to the disclosedembodiments. These exemplary screen displays may also, or instead, beencountered by a vendor in completing an evaluation requested by anentity, as part of one or more processing activities.

FIG. 35 depicts the exemplary listing 3520 of one or more vendors in adatabase as represented in the exemplary interface 3510. The listing3520 may include one or more vendors with which an entity is alreadyengaging in one or more contracts. Each item listed in the listing 3520may include vendor information, which may include: (1) the vendor'sname; (2) a product provided by the vendor; (3) a risk score for thevendor or the vendor's product(s); (4) a criticality rating for thevendor (or vendor's product); (5) a business unit for which the vendorprovides services; (6) an privacy impact assessment status for thevendor (or vendor's product) (e.g., does the entity have a currentprivacy impact assessment for the vendor); and (7) a current status ofthe vendor. Some portion of the listing for each vendor shown in thelisting 3520 may be a user-selectable control (e.g., a user-selectableindicia, a webpage control, etc.) that, when selected and/or otherwiseactivated, presents the user with additional vendor information asdescribed herein.

The exemplary interface 3510 may also include a user-selectable control3530 for adding a new vendor to the database of vendor information. Inresponse to the user selecting the control 3530, the system may beconfigured to generate the interface 3610 shown in FIG. 36 which mayfacilitate the creation of a new database entry for the new vendor. Thesystem may access a prepopulated database of potential vendorinformation and use such information to provide a listing of one or morepotential vendors 3630 from which a user may select a vendor. The systemmay also allow a user of the interface 3610 to search for a particularvendor from among those available in a database of potential vendorusing a search field 3620. In some examples, the system may populate adrop-down box 3621 based on the user's input to the search field 3620,allowing the user to select a vendor from the drop-down box 3621. Shouldthe user not locate the desired vendor from the listing of vendorsprovided by the interface 3610, the user may select the control 3640 toadd a new vendor without using prepopulated information.

Upon selection of a vendor from the prepopulated listing on theinterface 3610 or selection of the control 3640 to add a new vendorwithout using predetermined information, the system may generate anexemplary interface 3710 of FIG. 37. Where the user has selected aparticular vendor as the vendor to be added to a database of vendorinformation (e.g., by selecting a vendor on the interface 3610 of FIG.36), the system may prepopulate some or all of the field and informationshown in the interface 3710. Where the user has chosen to add a newvendor without using predetermined information, some or all of the fieldand information shown in the interface 3710 may be left blank.

The fields available in the interface 3710 may include the vendorinformation fields 3720 (e.g., in the example of FIG. 37, for ABC, Inc.,an audit and financial advisory firm). The vendor information fields3720 may include respective fields for: (1) a vendor name; (2) a vendordescription; (3) one or more vendor addresses or locations (e.g., avendor headquarters address, a location within which the vendoroperates, a jurisdiction to which the vendor is subject, etc.); (4) oneor more vendor contacts; (5) contact information for the one or morevendor contacts; (6) respective roles and/or responsibilities of the oneor more vendor contacts; and/or (7) any other suitable vendorinformation. Some or all of the vendor information fields 3720 may beprepopulated based on known vendor information (e.g., in response to auser selecting a vendor on the interface 3610 of FIG. 36). The fieldsavailable in the interface 3710 may include a services field 3730 thatmay allow a user to select or view one or more of the services,products, software, offerings, etc. that the vendor may provide to theentity. The user may select and/or deselect such services asappropriate. Some or all of the services shown in the services field3730 may be preselected and/or prepopulated based on known vendorservices information (e.g., in response to a user selecting a vendor onthe interface 3610 of FIG. 36). The system may be configured to enable auser to update any information (e.g., that may be incorrect ornon-current) that may have been prepopulated.

Upon entry or receipt of vendor information (e.g., as described inregard to FIG. 37), the system may be configured to enable a user toupload one or more documents associated with the vendor(e.g., one ormore licenses, agreements, contracts, etc. that an entity may beentering into and/or engaged in with the vendor). To facilitate thisdocument uploading, the system may generate an interface such as theexemplary interface 3810 shown in FIG. 38. The interface 3810 may beconfigured to receive one or more documents for uploading and analysis,for example using the upload field 3820. The interface 3810 may alsodisplay a listing 3830 of documents that have already been uploaded forthis particular vendor. Such a listing may be prepopulated based on anearlier selection of the particular vendor (as described in regard toFIG. 36) and/or may reflect documents already uploaded using theinterface 3810.

Upon receipt of one or more documents associated with the vendor, thesystem may be configured to analyze such one or more documents using anysuitable analysis technique (e.g., natural language processing) toidentify key language and/or terms in the documents. The system may, forexample, be automatically configured to identify, from such documents,one or more of: (1) term limits; (2) breach notification timelineobligations; (3) sub-processor change notifications; (4) liability capsand/or obligations; (5) data breach liability information; (6)indemnification information; (7) data transfer mechanisms; (8)notification time periods for a breach; (9) notification requirementsfor sub-processor changes; and/or (10) any other suitable informationthat may be included in any documents associated with a vendor.

FIG. 39 depicts the exemplary interface 3910 showing results of suchanalysis. The system may be configured to indicate one or moreparticular identified features and/or terms of the documents in thecritical data section 3920, which may list such features and/or terms asone or more respective user-selectable controls associated with one ormore respective locations in the uploaded document where the particularidentified features and/or terms may be found. Upon selection of acontrol for a particular feature or term, the system may be configuredto display the document section from which the particular feature orterm was derived in the document display section 3930. For example, asshown in the interface 3910, the system has identified breachnotification requirements, liability obligations, and data transferobligations in the critical data section 3920. When the highlightedbreach notification requirements indicia in the critical data section3920 is selected, the system is configured to display the correspondingtext from the document from which such requirements were derived in thedocument display section 3930.

As described herein, the system may be configured to determine and/oranalyze publicly available information sources and/or shared informationsources that may have data associated with the vendor. Such informationsources may include one or more webpages (e.g., operated by the vendorand/or operated by third parties), databases to which the entity mayhave access, news sources, governmental bodies, regulatory agencies,industry groups, etc. FIG. 40 depicts the exemplary interface 4010 thatmay indicate to a user the information sources that are being analyzedin the listing 4020. In this analysis, the system may be configured touse any suitable analysis technique (e.g., natural language processing)to determine the desired vendor-related information. Among the analysisperformed by the system, the system may be configured to: (1) analyzeone or more local/privacy/jurisdiction laws associated with the vendor;(2) analyze shared data with the vendor; (3) analyze one or more consentwithdrawal obligations from one or more vendor documents; (4) analyzeone or more data subject requests associated with the vendor; and (5)analyze one or more sub-processors associated with the vendor.

FIG. 41 depicts the exemplary interface 4110 showing a vendor overview.The system may be configured to generate and display the vendor overviewinterface 4110 based on any vendor information the system hasdetermined, including information determined based on the vendoranalyses described herein. The interface 4110 may include a descriptionof the vendor (e.g., “ADB, Inc.” in FIG. 41) in the vendor descriptionsection 4120 that may include the vendor's name, location, description,etc.

The system may be configured to determine additional information for thevendor based on one or more of: (1) information gathered from the vendor(e.g., assessment responses from the vendor); (2) information about thevendor gathered from public or shared sources (e.g., webpages,databases, etc.); documents associated with the vendor (e.g., contracts,licenses, agreements, etc.); and/or (3) and other vendor information(e.g., known vendor data, historical information about the vendor,etc.). Such additional information may be displayed on the interface4110.

In various embodiments, as part of additional vendor information, thesystem may calculate a vendor risk score for the vendor, shown as“Vendor Score” in the vendor score section 4170 of the interface 4110.As described herein, the system may, for example, calculate the vendorrisk score based on any factor(s) and/or criteria described herein orthat may be suitable (e.g., information transfer, contract terms,assessments performed, etc.). The system may also calculate one or moreother scores (e.g., as one or more internal vendor-related scores basedon criteria different than that used to determine a vendor risk score)and display such scores in the vendor score section 4170.

In various embodiments, as part of additional vendor information, thesystem may determine and/or highlight one or more vendor risks (e.g.,data encryption incidents, personal information compromises, 3^(rd)party breaches, etc.) and display such risks in the vendor risk section4130. In various embodiments, as part of additional vendor information,the system may determine and display third-party vendors utilized by thevendor in the third-party vendor section 4140. In various embodiments,as part of additional vendor information, the system may determine anddisplay historical incidents associated with the vendor in thehistorical incident section 4150. In various embodiments, as part ofadditional vendor information, the system may determine and display alisting of services provided by the vendor in the services listing 4160.The system may be configured to determine and display any otherinformation relevant to risks associated with the vendor.

FIG. 42 depicts the exemplary interface 4210 showing vendor details. Thesystem may be configured to generate and display the vendor detailsinterface 4210 based on any vendor information the system hasdetermined, including information determined based on the vendoranalyses described herein. The interface 4210 may include any vendorinformation described herein, including the vendor information shown inthe section 4240 of the interface 4210, and vendor information such as:(1) a number of security and/or privacy officers (e.g., as shown in thesection 4220 of the interface 4210); (2) one or more certifications,verifications, and/or awards obtained by the vendor (e.g., as shown inthe section 4230 of the interface 4210); (3) one or more vendor contactsand their respective roles at the vendor organization (e.g., as shown inthe section 4250 of the interface 4210); (4) entity personnelresponsible for interacting with the vendor and their respective rolesat the entity organization (e.g., as shown in the section 4260 of theinterface 4210); (5) notes regarding interactions with the vendor andrelated information (e.g., as shown in the section 4270 of the interface4210); and/or (6) any other information that may be of use in evaluatingand interacting with the vendor.

As described herein, a vendor may complete one or more privacy and/orsecurity-related assessments (e.g., that may include question/answerpairings), the responses to which the system may use in calculating oneor more vendor risk scores and/or determining other vendor information.FIG. 43 depicts the exemplary interface 4310 for requesting that anassessment be sent to a vendor. The system may be configured to detectthe selection of a vendor from the listing of vendors 4320 and/or theselection of the assessment control 4330. Responsive to such detection,the system may be configured to request desired assessment information,for example using the assessment information window 4340. The assessmentinformation window 4340 may include fields or selections that allow auser to specify a template for the assessment (e.g., as shown in thefield 4341), a name for the assessment (e.g., as shown in the field4342), and a recipient of the assessment, such as a particular vendoremployee or representative to designated to received such an assessment(e.g., as shown in the field 4343).

After completion of an assessment request (e.g., as described in regardto FIG. 43), a designated vendor representative may receive anindication that a new assessment has arrived. FIG. 44 depicts theexemplary interface 4410 that may include a notification 4420 of a newassessment. Note that the system may be configured to generate such aninterface in response a user requesting that such an assessment be sentbecause vendor information queried by the assessment has expired, asdescribed herein. The assessment notification 4420 may include a controlthat allows the recipient vendor representative to initiate theassessment.

At least partially in response to initiating the assessment, the systemmay be configured to present the exemplary interface 4510 as shown inFIG. 45 that may request information using, for example, one or morequestion and answer pairs (e.g., as described herein). For example, thefirst question and answer section 4520 may be presented to the vendorrepresentative completing the assessment, followed by the secondquestion and answer section 4530 that may, in some examples, not beactive until the preceding question and answer section is complete. Uponcompleting the required one or more question and answer sections of theassessment, the vendor representative may activate the assessmentsubmission control 4540 to submit the completed assessment to the entityrequesting the assessment.

In various embodiments, answers to one or more questions within a vendorassessment may be pre-populated based on known and/or previouslyprovided information. This may be especially helpful where a subset ofinformation acquired via an assessment has expired but the remaininginformation remains valid. In such embodiments, the system may beconfigured to generate and present an interface that includesprepopulated information, such as the exemplary interface 4610 shown inFIG. 46. In this example, the system may generate a window including thesection of prepopulated information 4620 that the vendor representativemay then evaluate and update as needed.

The system may be configured to detect a change in a vendor'sinformation and responsively inquire of a user whether the vendor shouldbe sent an updated assessment. In various embodiments, the system may beconfigured to substantially automatically identify a change in asub-processor by one or more vendors. The system may, for example, beconfigured to monitor one or more RSS feeds to identify one or morechanges to one or more sub-processors utilized by a particular vendor.In response to identifying that a vendor has changed (e.g., been addedor removed) one or more sub-processors, the system may be configured tosubstantially automatically generate and/or transmit a privacyassessment and/or a security assessment to the vendor based at least inpart on the detected change. Alternatively, the system may be configuredto prompt a user to send a new assessment.

FIG. 47 depicts the exemplary interface 4710 that includes thenotification 4720 of a detected vendor change. The notification 4720includes a user-selectable control that may initiate creation and/ortransmission of a new vendor assessment (e.g., as described herein).Note that any detected vendor changes may initiate a new vendorassessment and/or generate a prompt to a user inquiring of the need tosend a new assessment to the vendor.

FIGS. 48-50 depict exemplary screen displays that a user may encounterwhen utilizing any suitable system described herein to determine therisk (e.g., privacy risk, security risk, etc.) that a particular vendormay present, as well as to view other attributes and information aboutthe particular vendor. For example, these exemplary screen displays maybe encountered by a user associated with an entity in evaluating avendor to determine whether to begin or continue a relationship (e.g.,business relationship) with such a vendor according to various disclosedembodiments.

FIG. 48 depicts an exemplary listing 4830 of vendors in a database asrepresented in an exemplary user interface 4810. The system may access aprepopulated database of vendor information and use such information toprovide the listing of vendors 4830 from which a user may select avendor. The system may also allow a user of the interface 4810 to searchfor a particular vendor from among those available in a database ofvendor information using a search field 4820. In some examples, thesystem may populate a drop-down box 4821 based at least in part on theuser's input to the search field 4820, allowing the user to select avendor from the drop-down box 4821. Should the user not locate thedesired vendor from the listing of vendors provided by the interface4810, the user may select a control 4840 to add, or request to haveadded, a new vendor to the vendor information database. The user maythen take the necessary steps to add or request to add the new vendor.

Upon selection of a particular vendor on interface 4810, the system maygenerate exemplary interface 4910 as depicted in FIG. 49 on a displayscreen. The exemplary interface 4910 may show a vendor overview for theparticular vendor. The system may be configured to generate and displaythe vendor overview interface 4910 based at least in part on any vendorinformation the system has determined, including information determinedbased at least in part on the vendor analyses described herein. Theinterface 4910 may include a description of the vendor (e.g., “ABC,Inc.” in FIG. 49) in a vendor description section 4920, which mayinclude the vendor's name, location, description, etc.

The system may be configured to determine additional information for thevendor as described herein, including based at least in part on one ormore of: (1) information gathered from the vendor (e.g., assessmentresponses from the vendor); (2) information about the vendor gatheredfrom public and/or shared sources (e.g., webpages, databases, etc.);documents associated with the vendor (e.g., contracts, licenses,agreements, etc.); and/or (3) and other vendor information (e.g.,publicly known vendor data, historical information about the vendor,etc.). Such additional information may be displayed on interface 4910.

In various embodiments, as part of the additional vendor information,the system may calculate a vendor risk score (e.g., vendor security riskscore, vendor privacy risk score, etc.) for the vendor, shown as “VendorScore” in a vendor score section 4970 of interface 4910. As describedherein, the system may, for example, calculate the vendor risk scorebased at least in part on any factor or criteria described herein or anyother suitable information (e.g., information transfer information, oneor more contract terms, assessments previously performed for the vendor,etc.). The system may also calculate one or more other scores of anytype (e.g., as one or more internal vendor-related scores based at leastin part on criteria that differs from criteria used to determine one ormore other vendor risk scores) and display such scores in the vendorscore section 4970.

In various embodiments, as part of additional vendor information, thesystem may determine and/or highlight one or more vendor risks (e.g.,data encryption incidents, personal information compromises, third-partybreaches, etc.) and display such risks in the vendor risk section 4930.In various embodiments, as part of the additional vendor information,the system may determine and display third-party vendors utilized by thevendor in the third-party vendor section 4940. In various embodiments,as part of the additional vendor information, the system may determineand display one or more historical incidents associated with the vendorin the historical incident section 4950. In various embodiments, as partof the additional vendor information, the system may determine anddisplay a listing of services provided by the vendor in a serviceslisting 4960. The system may be configured to determine and display anyother information relevant to one or more privacy risks associated withthe vendor. The system may be configured to determine whether, based,for example, on any vendor information described herein, the particularvendor is approved or rejected for use by, and/or interaction with, theentity requesting the assessment of the vendor's risk. Based at least inpart on this determination, the system may present an approvalindication or a rejection indication in an approval section 4980 of theuser interface.

FIG. 50 depicts an exemplary interface 5010 showing vendor details. Thesystem may be configured to generate and display the vendor detailsinterface 5010 in response to a selection, by a user, of a particularvendor on interface 4810 of FIG. 48, for example, as an alternative todisplaying interface 4910 of FIG. 49, or in response to a selection, bya user, of a control on interface 4910 of FIG. 49 requesting furthervendor details. In various embodiments, the system may generateinterface 5010 based at least in part on any vendor information thesystem has determined, including information determined based at leastin part on the vendor analyses described herein. The interface 5010 mayinclude any additional detailed vendor information described herein,including the vendor information shown in the section 5040 of theinterface 5010, and vendor information such as: (1) a number of securityand/or privacy officers associated with the vendor (e.g., as shown insection 5020); (2) one or more certifications, verifications, and/orawards obtained by the vendor (e.g., as shown in section 5030); (3)vendor employees (e.g., employees who serve as contacts with therequesting entity) and their roles at the vendor organization (e.g., asshown in section 5050); (4) entity personnel responsible for interactingwith the vendor and their roles at the entity organization (e.g., asshown in section 5060); (5) notes regarding one or more interactionswith the vendor and related information (e.g., as shown in section5070); and (6) any other information that may be of use in evaluatingand interacting with the vendor. As noted above, in various embodiments,the system may be configured to determine whether, based at least inpart on any vendor information described herein, the particular vendoris approved or rejected for use by, and/or for interaction with, theentity requesting the assessment of the vendor's privacy risk. Based atleast in part on this determination, the system may present an approvalindication or a rejection indication in approval section 5080.

Exemplary Vendor Training Material Generation Experience

FIGS. 51-53 depict exemplary screen displays that a user may encounterwhen utilizing any suitable system described herein to generate and/orupdate training material associated with a particular vendor, as well asto view other attributes and/or information about the particular vendor.For example, these exemplary screen displays may be encountered by auser associated with an entity who may be operating the disclosed systemto obtain privacy-related training material and/or security-relatedtraining material that may assist the user in understanding how tointeract with a particular vendor. In another example, these exemplaryscreen displays may be encountered by a user associated with a vendorwho may be operating the disclosed system to obtain privacy-relatedtraining material and/or security-related training material provided byan entity with which the vendor interacts.

FIG. 51 depicts the exemplary listing 5130 of vendors in a database asrepresented in the exemplary interface 5110. The system may access aprepopulated database of vendor information and use such information toprovide the listing of vendors 5130 from which a user may select avendor. The system may also allow a user of the interface 5110 to searchfor a particular vendor from among those available in a database ofvendor information using the search field 5120. In some examples, thesystem may populate the drop-down box 5121 based at least in part on theuser's input to the search field 5120, allowing the user to select avendor from the drop-down box 5121.

Upon selection of a particular vendor on the interface 5110, the systemmay generate the exemplary interface 5210 showing a vendor overview forthe particular vendor, as depicted in FIG. 52. The interface 5210 mayinclude the user-selectable control 5280 that may indicate that trainingmaterial has been generated for the particular vendor. Theuser-selectable control 5280 may allow a user to download or otherwiseaccess (e.g., via a subsequent interface) the training materialgenerated by the system.

In various embodiments, the interface 5210 may also provide a date ofgeneration of such training material (e.g., on or proximate to theuser-selectable control 5280). The system may also be configured togenerate and/or display the vendor overview interface 5210 based atleast in part on any vendor information the system has determined,including information determined based at least in part on the vendoranalyses described herein. The interface 5210 may include a descriptionof the vendor (e.g., “ABC, Inc.” in FIG. 52) in vendor descriptionsection 5220, a “Vendor Score” in vendor score section 5270, one or morevendor risks in vendor risk section 5230, third-party vendors utilizedby the vendor in third-party vendor section 5240, historical incidentsassociated with the vendor in historical incident section 5250, alisting of services provided by the vendor in services listing 5260,etc.

As noted herein, the system may be configured to detect a change in avendor's information and/or an occurrence involving a vendor andresponsively update training material associated with that particularvendor. For example, the system may be configured to substantiallyautomatically identify a change in sub-processor by one or more vendors.FIG. 53 depicts the exemplary interface 5310 that includes anotification 5320 of a detected vendor change of a sub-processor. Thenotification 5320 includes a user-selectable control that may allow auser to download and/or otherwise access training material that has beenupdated based at least in part on the detected change or occurrence(e.g., as described herein). Alternatively, in response to selection ofthe user-selectable control 5320, the system may generate an interfacesuch as interface 5210 of FIG. 52. The user may then access the updatedtraining material using such an interface. Referring again to FIG. 52,where the system has generated updated training material in response tosome detected change or occurrence, the indication of such trainingmaterial generation (e.g., control 5280) may include a date of creation(e.g., updating) of such updated training material.

Mapping of Data Breach Regulation Questions

A large number of regulations govern the actions that are required to betaken in response to a data breach. The particular regulations thatapply to a data breach may be defined by the jurisdiction (e.g.,country, state, defined geographic area, or other suitable region, suchas any defined area sharing at least one common reporting requirementrelated to one or more data breaches) in which the data breach occurs,the nationality of one or more potential victims (e.g., data subjects)of the data breach, and/or the business sector involved in the databreach (e.g., healthcare, finance, telecommunications, utilities,defense, cybersecurity, etc.). For example, a data breach that resultsin the improper disclosure of personal health information within theU.S. may trigger the disclosure provisions of the Health InsurancePortability and Accountability Act (HIPAA). Examples of securitystandards or regulations that may indicate how a data breach is to bemanaged may include International Organization for Standardization (ISO)27000 series standards, National Institute of Standards and Technology(NIST) standards, Health Information Technology for Economic andClinical Health (HITECH) standards, Health Insurance Portability andAccountability Act (HIPAA) standards, American Institute of CertifiedPublic Accountants (AICPA) System and Organization Controls (SOC)standards, the EU General Data Protection Regulation (GDPR), and theCalifornia Consumer Privacy Act (CCPA). Jurisdictions may also developand use their own sets of requirements for handling data beaches.Entities (e.g., corporations, organizations, companies, etc.) may alsohave their own requirements and policies regarding the management ofdata breaches.

Therefore, a breach of personal data by a large, multinational companymay trigger a need to analyze and comply with (potentially numerous)applicable privacy regulations of a potentially large number ofdifferent territories. This can pose a daunting challenge for anorganization because, in currently available systems, a privacy officerwould typically have to complete a data breach disclosure questionnairefor each affected territory and/or business segment. Each suchquestionnaire can include a large number of (e.g., 40, 50, or more)questions, making this process very time consuming when there are manydifferent jurisdictions involved.

Systems and methods according to various embodiments may store, inmemory, an ontology that maps respective questions from a data breachdisclosure questionnaire for a first territory and/or business sector(e.g., an initial, high-level questionnaire that is used to determinewhether it is necessary to disclose a particular data breach within thefirst territory) to: (1) corresponding questions within one or more databreach disclosure questionnaires (e.g., similar thresholdquestionnaires) for other territories and/or business sectors; and/or(2) corresponding questions within a master questionnaire. For example,the health care sectors of Germany, France, and the United States mayall use “The number of data subjects whose data was affected by thebreach” as a factor in determining whether a particular breach must bedisclosed, who the breach must be disclosed to, and/or how quickly thebreach must be disclosed. In various embodiments, however, eachjurisdiction may include one or more data breach disclosurequestionnaire questions related to the number of data subjects withaffected data that are in a different form, in a different language, areworded differently, are posed differently (e.g., one questionnaire mayrequire a free-form text entry response, another may include one or moreuser selectable responses, etc.), etc. As may be understood in light ofthis disclosure, although each respective questionnaire may include oneor more respective questions that have different wording or form, eachquestion may still map back to the same specific question within a databreach master questionnaire.

In an example embodiment, the master questionnaire may include thequestion “How many data subjects were affected by the breach?” Thisquestion may be important because various jurisdictions may have varyingthreshold of affected numbers of data subject that trigger reportingrequirements. The system may map this question, via the ontology (whichmay map questions, at least in part, based on pattern matching betweenrespective questions), to corresponding questions within the respectivethreshold data breach questionnaires for Germany, France, and the UnitedStates. In a particular example, in response to receiving, from a user,an answer to this question in the master questionnaire, the system maythen use the answer in conjunction with the ontology to populate theanswer to the corresponding questions within the questionnaires forGermany, France, and the United States. For example, if the userindicated in the answer to this question in the master questionnairethat the personal data of 150 people was affected by the breach, thesystem may save, in system memory, an answer corresponding to “150people” to the particular question “How many data subjects were affectedby the breach” (or similar questions that may, for example, be wordeddifferently) in the threshold data breach questionnaires for Germany,France, and the United States.

It should be understood that the ontology may vary in complexity basedon the circumstances. In particular embodiments, one or more questionsfrom a master questionnaire (e.g., 1, 2, 3, 4, 5, 10, 25, 50, etc.questions) may each be respectively mapped to one or more correspondingquestions in a plurality of (e.g., any number between 1 and 500, ormore) data breach questionnaires for respective territories and/orbusiness sectors. For example, the question above regarding the numberof affected data subjects may be mapped to a respective question in databreach questionnaires for 40 different jurisdictions.

The system may include any number and type of questions in a masterquestionnaire and any data breach questionnaire for a particularterritory and/or business sector. The system may use the answers to anysuch questions to determine the notification obligations for anyparticular territory. In this way, the system may determine thenotification obligations for various territories that may each havevarying disclosure requirements. The questions that the system mayinclude on a master questionnaire and/or a data breach questionnaire fora particular territory may include, but are not limited to, a number ofaffected data subject and/or consumers, types of data elements involvedin the breach, a volume of data involved in the breach, a classificationof data involved in the breach, a business sector associated with thebreach, questions associated with any type of regulatory trigger thatmay initiate a requirement for disclosure, etc.

FIG. 54 illustrates an exemplary Data Structure 5400 representing a databreach ontology according to particular embodiments that may be used fordetermining data breach response requirements and/or gathering databreach reporting information. The Data Structure 5400 may includerequirements for each territory and/or business sector regarding, forexample, what types of data breaches must be disclosed (e.g., whether aparticular type of data breach must be disclosed and to whom), whendifferent types of affected breached need to be disclosed (e.g., one ormore reporting deadlines), and/or how different types of data breachesneed to be disclosed (e.g., what information needs to be reported, theform of reporting, etc.). The Data Structure 5400 may also facilitatethe gathering of data for, and the reporting of, data breaches.

The Data Breach Master Questionnaire 5410 represents data received asanswers to a master questionnaire that the system provided to a user.The system may map answers to questions in the master questionnaire tocorresponding answers for one or more other questionnaires. For example,the system may map one or more answers for the Master Questionnaire 5410to one or more answers for the Data Breach Disclosure Questionnaire forGermany 5420 and/or the Data Breach Disclosure Questionnaire for France5430, as shown in FIG. 54. The system may also, or instead, map answersto questions in any particular questionnaire to corresponding answersfor any one or more other questionnaires. For example, the system maymap one or more questions for the Data Breach Disclosure Questionnairefor Germany 5420 to one or more questions for the Data Breach DisclosureQuestionnaire for France 5430, as shown in FIG. 54.

For example, the system may map data associated with question 5410A ofthe Data Breach Master Questionnaire 5410, which may provide a number ofdata subjects affected by a data breach, to question 5420A for the DataBreach Disclosure Questionnaire for Germany 5420 and to question 5430Cfor the Data Breach Disclosure Questionnaire for France 5430. Also, orinstead, the system may map data associated with question 5420A for theData Breach Disclosure Questionnaire for Germany 5420 to question 5430Cfor the Data Breach Disclosure Questionnaire for France 5430. The systemmay also, or instead, map data associated with question 5410B of theData Breach Master Questionnaire 5410, which may provide a date for thedetection of a data breach, to question 5420L for the Data BreachDisclosure Questionnaire for Germany 5420, but not to a question in theData Breach Disclosure Questionnaire for France 5430. The system mayalso, or instead, map data associated with question 5410Y of the DataBreach Master Questionnaire 5410 to question 5430FH for the Data BreachDisclosure Questionnaire for France 5430, but not to a question in theData Breach Disclosure Questionnaire for Germany 5420. In variousembodiments, an ontology may map any one or more questions of anyquestionnaire to any one or more questions in any one or more otherquestionnaires in the ontology, or to no question in any otherquestionnaire.

One potential advantage of various embodiments of computer-implementedversions of this ontology is that it may allow a user to effectivelycomplete at least a portion of a large number of data breachquestionnaires by only completing a single master questionnaire. Invarious embodiments, the system may prompt the user to input answers toeach respective question in the master questionnaire. The system wouldthen map the answer to each of the questions to also be the answer ofany corresponding questions in the data breach questionnaires of anyother countries in which the entity was doing business or that wereinvolved in a particular data breach (e.g., as determined by input froma user).

In particular embodiments, the system may be configured to dynamicallyedit the current master questionnaire for a particular entity so thatthe master questionnaire includes, for example, at least one questionthat will provide the answer for each question within a data breachdisclosure questionnaire of a plurality of territories in which theentity does business (e.g., all of the territories in which the entitydoes business) or that were involved in a particular data breach (e.g.,all of the territories affected by the particular data breach).

For example, in a particular embodiment, if a data breach disclosurequestionnaire includes a question that is unique to Brazil, the masterquestionnaire will include that question as long as the entity's profileinformation indicates that the entity is doing business in Brazil orthat Brazil is involved in the associated data breach. However, if auser modifies the entity's profile information to indicate that theentity no longer does business in Brazil, the system may automaticallymodify the master questionnaire to remove the question (since thequestion will no longer be applicable to the entity). Similarly, if auser even later updates the entity's profile to indicate that the entityhas resumed doing business in Brazil, the system may automaticallyupdate the master questionnaire to include the Brazil-specific question(and/or questions).

In various embodiments, the system may be configured to generate amaster questionnaire at any appropriate time. For example, in aparticular embodiment, the system may prompt a user to indicate one ormore territories (e.g., regions, jurisdictions, and/or countries) and/orsectors in which an entity is doing business and, at least partially inresponse to receiving the user's input, generate a threshold list ofquestions that the system may then use to determine which territoriesrequire disclosure of a particular data breach. In another particularembodiment, the system may prompt a user to indicate one or moreterritories (e.g., regions, jurisdictions, and/or countries) and/orsectors affected (e.g., potentially affected) by a particular databreach and, at least partially in response to receiving the user'sinput, generate a threshold list of questions that the system may thenuse to determine which territories affected by the data breach requiredisclosure of the data breach.

For example, in a particular embodiment, after a user identifies aparticular data breach, the system may responsively execute a disclosurecompliance module, such as the exemplary Disclosure Compliance Module5500 shown in FIG. 55. In executing the Disclosure Compliance Module5500, at Step 5510, the system may prompt the user to indicate theterritories (e.g., regions, jurisdictions, countries, etc.) in which theentity does business. Alternatively, or in addition, at Step 5510, thesystem may prompt the user to indicate the territories that may beaffected by the particular data breach. In various embodiments, thesystem may ask the user to select territories from a listing ofterritories. Alternatively, or in addition, the system may prompt theuser to indicate the applicable territories using any suitabletechnique. Further at Step 5510, the system may receive input from theuser indicating the applicable territories. In particular embodiments,the system may facilitate such prompting for territories and receipt ofindications of applicable territories by using graphical userinterfaces.

Next, at Step 5520, the system may prompt the user to indicate thebusiness sectors (e.g., healthcare, finance, etc.) in which the entityis doing business. Alternatively, or in addition, at Step 5510, thesystem may prompt the user to indicate the business sectors that may beaffected by the particular data breach. In various embodiments, thesystem may ask the user to select business sectors from a listing ofbusiness sectors. Alternatively, or in addition, the system may promptthe user to indicate the applicable business sectors using any suitabletechnique. Further at Step 5520, the system may receive input from theuser indicating the applicable business sectors. In particularembodiments, the system may facilitate such prompting for businesssectors and receipt of indications of applicable business sectors byusing one or more graphical user interfaces.

In response to the user-indicated applicable territories and/orbusiness, at Step 5530 the system may generate a master questionnaire ofthreshold questions for the applicable territories and business sectors,e.g., as described above. At Step 5540, the system may present themaster questionnaire to the user and prompt the user for inputindicating answers to the threshold questions in the masterquestionnaire. Further at Step 5540, the system may receive input fromthe user indicating answers to the threshold questions in the masterquestionnaire. The system may prompt the user to indicate the answers tothe threshold questions using any suitable techniques. In particularembodiments, the system may facilitate such prompting for answers to thethreshold questions and receipt of indications of answers to thethreshold questions by using graphical user interfaces.

At Step 5550, the system may use the ontology to map the user's answersto the threshold questions in the master questionnaire back to thethreshold questionnaires for each particular applicable territory and/orbusiness sector. At Step 5560, the system may to determine based on theinformation mapped from the master questionnaire answers to thethreshold questionnaires for each particular applicable territory and/orbusiness sector, whether, under the applicable laws of each particularapplicable territory and/or within the particular applicable businesssector, the entity must disclose the data breach (e.g., in addition tothe matter of any required disclosure, timing of any requireddisclosure, etc.). In various embodiments, the system may be configuredto determine a respective disclosure requirement for each of one or moreterritories and/or one or more business sectors in which a particularentity operates. In particular embodiments, the system is configured tosimultaneously determine, for at least two or more jurisdictions inwhich the entity operates, a respective disclosure requirement for eachof the at least two or more jurisdictions (e.g., the system isconfigured to determine the respective disclosure requirements for eachof the at least two or more jurisdictions in parallel). The system may,for example, utilize one or more parallel processing techniques.

If so, at Step 5570, the system generates one or more disclosurequestionnaires, each of which may reflect questions from a breachnotification template for a particular territory and/or business sector,for completion by the user. Alternatively, the system may generate oneor more disclosure questionnaires that may each include a consolidatedmaster list of disclosure questions that are respectively mapped (e.g.,using the ontology) to any one or more corresponding questions in one ormore respective disclosure questionnaires (e.g., breach notificationtemplates) for each of the territories in which the entity is requiredto disclose the breach (e.g., as determined by the system).Alternatively, or in addition, the system may facilitate the usercompleting a breach notification template for each territoryindividually. At Step 5580, the system may present the one or moredisclosure questionnaires to the user and prompt the user for inputindicating answers to the questions in each disclosure questionnaire.Further at Step 5580, the system may receive input from the userindicating answers to the questions in each disclosure questionnaire.The system may prompt the user to indicate the answers to questions ineach disclosure questionnaire using any suitable techniques. Inparticular embodiments, the system may facilitate such prompting foranswers to the questions in each disclosure questionnaire and receipt ofindications of answers to the questions in each disclosure questionnaireby using graphical user interfaces. The system may then use the answersto the questions in each disclosure questionnaire to generate theapplicable disclosure document(s) for each territory.

At Step 5590, after receiving the user's answers to the questions ineach disclosure questionnaire, the system may use the input receivedfrom the user (e.g., when completing the master questionnaire and/orwhen providing answers to the questions in each disclosurequestionnaire) to automatically generate a suitable disclosure documentdisclosing the breach for each territory in which disclosure of thebreach is required. The system may then access, from system memory,information regarding how to properly submit the required disclosuredocument to each territory and display that information to the user.This information may include, for example, a mailing address or emailaddress to which the disclosure document must be submitted, the entityor person to which the disclosure document should be sent, etc. In aparticular embodiment, the system may be adapted to auto-submit one ormore of the disclosure documents to the entity or person to which thedisclosure document should be sent (e.g., via a suitable electronic orpaper transmission of the document).

In various embodiments, the system may be adapted to present questionsfor a particular jurisdiction in the order in which they are presentedon the jurisdiction's disclosure form. This may make it easier for theindividual to prepare and finalize the disclosure form. In particularembodiments, the system may be further adapted to, based on a user'sanswers to one or more of the master list of disclosure questions,automatically promote an incident to a breach status.

In various embodiments, the system may be configured to present theresults of the disclosure determination using a graphical userinterface. FIG. 56 depicts an exemplary interface 5600 showing theresults of a disclosure determination as described herein (e.g., by theDisclosure Compliance Module 5500). The system may indicate on interface5600 the territories for which the system has determined that disclosureis required. The system may also indicate on such an interface theterritories for which the system has determined that disclosure is notrequired. The interface 5600 may include a graphical representation ofone or more territories, such as map 5610. The system may color code,shade, or otherwise visually indicate which of the territories shown inthe map 5610 require notification of a data breach and which do not. Thesystem may also color code, shade, or may otherwise visually indicatewhich of the territories shown in the map 5610 are not territories inwhich the entity is conducting business (and therefore were not includedin the disclosure analysis performed by the system). The system maygenerate a legend 5620 in the interface 5600 to illustrate to the userthe meaning of the color coding, shading, visual indications, etc. usedon the map 5610 to illustrate the disclosure status of each territoryand/or whether each territory was included in the disclosure analysis.

The interface 5600 may also include details of the disclosurerequirements determined by a data breach disclosure determination asdescribed herein. For example, the system may present disclosurerequirements listing 5630 on the interface 5600 listing data breachnotification requirements for the various jurisdictions in whichdisclosure is required. The interface 5600 may also include details ofeach particular disclosure requirement for a territory in whichdisclosure is required. For example, the system may present disclosurerequirement subtasks listing 5640 on the interface 5600 listingparticular subtasks associated with a particular data breachnotification requirement for a particular territory in which disclosureis required, such as the territory highlighted in the disclosurerequirements listing 5630.

The system may also present further detailed information regarding thedisclosure requirements for a particular territory for which the systemhas determined that disclosure of the data breach is required. FIG. 57depicts an exemplary interface 5700 showing detailed results of adisclosure determination as described herein (e.g., by the DisclosureCompliance Module 5500) for a particular territory. The interface 5700may include a graphical representation of one or more territories, suchas map 5710. Upon selection of one of these territories, the system mayhighlight the selected territory, for example, the selected territory5715 on the interface 5700. The system may then, in response to userselection of the selected territory 5715, generate detailed informationregarding the selected territory 5715 in the detailed informationsection 5720. The detailed information section 5720 may include detailedinformation regarding the reporting requirements for the selectedterritory 5715, such as the particular laws or regulation that requiredisclosure, the regulating body, contact information for the regulators,etc.

As in FIG. 56, the interface 5700 of FIG. 57 may also include details ofthe disclosure requirements determined by a data breach disclosuredetermination as described herein, such as disclosure requirementslisting 5730 listing data breach notification requirements for thevarious jurisdictions in which disclosure is required and disclosurerequirement subtasks listing 5740 on listing particular subtasksassociated with a particular data breach notification requirement forthe selected territory 5715.

In any embodiment described herein, they system may be configured to atleast partially automatically determine and populate one or moreresponses to one or more questions in the master questionnaire (e.g.,prior to mapping the one or more responses to a correspondingquestionnaire for a particular jurisdiction and/or business unit). Thesystem may, for example, use one or more data mapping techniques (suchas any data mapping technique described herein), for example, todetermine particular data subjects involved, particular data assetsinvolved, a location of those data assets, a type of data elementsinvolved in the data breach, a volume of data subjects affected by thedata breach, a classification of data involved in the breach, and/or anyother suitable data related to the breach that may be relevant to one ormore reporting and/or disclosure requirements. The system may, invarious embodiments, at least partially automatically populate one ormore responses to a master questionnaire and: (1) optionally prompt auser to confirm the automatically populated responses; and (2) prompt auser to provide any additional responses that the system did notautomatically populate. In a particular example, in response to a databreach involving a payroll processing database utilized by an entity,the system may be configured to access a data model for the entity todetermine, for example: (1) a number of employees whose personal data(e.g., name, mailing address, banking information, etc.) may have beenaffected by the breach; (2) a type of data potentially exposed by thebreach (e.g., routing numbers, names, social security numbers, etc.);(3) a number of other entity data assets that may have been affected(e.g., by virtue of interfacing with the payroll processing database,sending or receiving data to the databased, etc.); and/or (4) any otherdata related to the payroll processing database that may be relevant todetermine what disclosure requirements may need to be met by the entityin response to the data breach. The system may then use the determineddata to at least partially automatically populate one or more masterquestionnaires (e.g., one or more responses in the one or more masterquestionnaires) for use in one or more breach disclosure assessments.

Assessing Entity and/or Vendor Compliance with Privacy Standards

Systems and methods according to various embodiments may store, inmemory, an ontology that maps respective controls that are required forcompliance with a first privacy standard (e.g., HIPAA, NIST, HITECH,GDPR, CCPA, etc.) to: (1) corresponding controls required for compliancewith one or more other privacy standards; and/or (2) respectivecorresponding questions within a master questionnaire. For example, eachof the HIPAA, NIST, and HITECH privacy standards may all requiremulti-factor authentication of employees before allowing the employeesto access sensitive data. Accordingly, the ontology may map, to eachother, respective controls listed in the HIPAA, NIST and HITECH privacystandards that each involve multi-factor authentication of employees.

The ontology may also, or alternatively, map each of the respectivecontrols listed in a privacy standard or required by a privacyregulation (e.g., HIPAA, NIST, HITECH, GDPR, CCPA, etc.) to a questionin a master list of questions that is used to determine compliance withthe one or more privacy standards and/or regulations. For example, themaster questionnaire may include a question regarding the use ofmulti-factor authentication of employees that maps to a requirement ofone or more privacy standards. Such a question may be, for example,“Does your organization require multi-factor authentication of employeesbefore they access sensitive data?”. In a particular example, inresponse to receiving the answer to this question in the masterquestionnaire from a user, the system may use the answer in conjunctionwith the ontology to populate the answer to the corresponding questionswithin particular questionnaires that are used to assess an entity'slevel of compliance with a plurality of privacy standards and/orregulations, where each particular questionnaire is specific to aparticular privacy standard or regulation (e.g., HIPAA, NIST, HITECH,CSA, GDPR, CCPA, etc.). For example, if the user indicated in the answerto this question in the master questionnaire that the user'sorganization does require multi-factor authentication of employeesbefore they access sensitive data, the system may save, in system memoryusing the ontology, an answer corresponding to “Yes” to that particularquestion (or similar questions that may, for example, be wordeddifferently) in the particular privacy standard compliancequestionnaires for HIPAA, NIST, and HITECH.

It should be understood that the ontology may vary in complexity basedon the circumstances. In particular embodiments, one or more questionsfrom the master list a master questionnaire (e.g., 1, 2, 3, 4, 5, 10,25, 50, etc. questions) may each be respectively mapped to one or morecorresponding questions in a plurality of (e.g., any number between 1and 500, or more) respective compliance questionnaires for other privacystandards. For example, the question above regarding multi-factorauthentication may be mapped to a respective question in compliancequestionnaires for 20 different privacy standards.

The system may include any number and type of questions in a masterquestionnaire and any compliance questionnaire for a particular privacyregulation and/or privacy standard. The system may use the answers toany such questions to determine whether and to what extent an entityand/or a vendor complies with a particular privacy regulation and/orprivacy standard. In this way, the system may determine vendor and/orentity compliance with various privacy regulations and/or privacystandards that may each have varying requirements. The questions thatthe system may include on a master questionnaire and/or a compliancequestionnaire for a particular privacy regulation and/or privacystandard may include, but are not limited to, controls on access tosensitive data, controls on modification and storage of sensitive data,required employee certifications, required security controls ondevices/websites/systems, and any other questions associated with anytype of control or requirement needed to comply with any privacystandard or privacy regulation.

FIG. 58 illustrates an exemplary Data Structure 5800 representing acompliance ontology according to particular embodiments that may be usedfor determining particular privacy standard/regulation compliance and/orgathering privacy standard/regulation compliance information. The DataStructure 5800 may include requirements for each particular privacystandard and regulation, for example, what types of controls must be inplace, what types of security measures are required, employeerequirements (e.g., training, certifications, background checks, etc.),physical requirements, software requirements, etc. The Data Structure5800 may also facilitate the gathering of data for, and thedetermination of, compliance with any one or more privacy standards andprivacy regulations.

The Compliance Master Questionnaire 5810 represents data received asanswers to a master questionnaire that the system provided to a user.The system may map answers to questions in the master questionnaire tocorresponding answers for one or more other questionnaires. For example,the system may map one or more answers for the Master Questionnaire 5810to one or more answers for the Privacy Standard Compliance Questionnairefor HIPAA 5820 and/or the Privacy Standard Compliance Questionnaire forNIST 5830, as shown in FIG. 58. The system may also, or instead, mapanswers to questions in any particular questionnaire to correspondinganswers for any one or more other questionnaires. For example, thesystem may map one or more questions for the Privacy Standard ComplianceQuestionnaire for HIPAA 5820 to one or more questions for the PrivacyStandard Compliance Questionnaire for NIST 5830, as shown in FIG. 58.

For example, the system may map data associated with question 5810A ofthe Compliance

Master Questionnaire 5810, which may indicate whether multi-factorauthentication is required, to question 5820A for the Privacy StandardCompliance Questionnaire for HIPAA 5820 and to question 5830C for thePrivacy Standard Compliance Questionnaire for NIST 5830. Also, orinstead, the system may map data associated with question 5820A for thePrivacy Standard Compliance Questionnaire for HIPAA 5820 to question5830C for the Privacy Standard Compliance Questionnaire for NIST 5830.The system may also, or instead, map data associated with question 5810Bof the Compliance Master Questionnaire 5810, which may provide anindication as to whether a particular certification is required foremployees, to question 5820L for the Privacy Standard ComplianceQuestionnaire for HIPAA 5820, but not to a question in the PrivacyStandard Compliance Questionnaire for NIST 5830. The system may also, orinstead, map data associated with question 5810Y of the ComplianceMaster Questionnaire 5810 to question 5830FH for the Privacy StandardCompliance Questionnaire for NIST 5830, but not to a question in thePrivacy Standard Compliance Questionnaire for HIPAA 5820. In variousembodiments, an ontology may map any one or more questions of anyquestionnaire to any one or more questions in any one or more otherquestionnaires in the ontology, or to no question in any otherquestionnaire.

One potential advantage of various embodiments of computer implementedversions of this ontology is that it may allow a user to effectivelycomplete at least a portion of a large number of privacy standard and/orregulation compliance questionnaires by only completing a single, masterquestionnaire. In various embodiments, the system may prompt the user toinput answers to each respective question in the master questionnaire.The system would then, using the ontology, map the answer to each of thequestions to also be the answer of any corresponding questions in therespective compliance questionnaires for any suitable privacy standards.

In particular embodiments, the system may be configured to dynamicallyedit the current master questionnaire for a particular entity or vendorso that the master questionnaire includes, for example, at least onequestion that will provide the answer for each question within a privacystandard compliance questionnaire of a plurality of data standards. Forexample, if a privacy standard compliance questionnaire includes aquestion that is unique to HIPAA, the master questionnaire will includethat question if a user indicates that they would like to assess anentity's compliance with HIPAA. However, if a user indicates that theentity (or the user) no longer wishes to assess the entity's compliancewith HIPAA, the system may automatically modify the master questionnaireto remove the question (since the question will no longer be applicableto the entity). Similarly, if a user later updates the entity's profileto indicate that the entity (or user) again wishes to evaluate theentity's compliance with HIPAA, the system may automatically update themaster questionnaire to include the HIPAA-specific question.

In various embodiments, the system may be configured to generate themaster questionnaire at any appropriate time. For example, in aparticular embodiment, the system may prompt the user to indicate theprivacy standards and/or regulations that the user would like to have anentity or vendor evaluated for compliance with before generating amaster list of questions that the system then uses to determine theextent to which the entity or vendor complies with the indicated privacystandards.

After a user provides answers to the questions in a master list, thesystem may uses the ontology to map the user's answers to the questionsback to the compliance questionnaires for each specified privacystandard and regulation to determine the extent to which the entity orvendor complies with each respective privacy standard and regulation. Invarious embodiments, the results of this determination may beselectively communicated to the user in any suitable way. For example,the system may generate and present to the user a report showing thedegree to which (e.g., in percentages) an entity complies with eachspecified privacy standard and regulation.

In particular embodiments, the system may be adapted to not re-presentquestions that the system already has answers for. In such embodiments,the system may only present, to the user, compliance questions forselected privacy standards that the system doesn't already have ananalogous answer for (e.g., based on an earlier-answered question from amaster list of questions and/or an earlier-answered question from acompliance question for another privacy standard or regulation.)

In particular embodiments, the system may be adapted to automaticallydetermine that a particular entity complies, fully or partially (e.g.,in regard to consent) with one or more particular standards (e.g., theHITECH standard) based on the entity's compliance with one or more otherstandards and/or the answers to various questions within a masterquestionnaire.

In various embodiments, the questions presented to a user (e.g., as partof a master questionnaire) may be answered based on different types ofinformation that may be associated with different levels of confidence.For example, each particular question may be answered with: (1)unsubstantiated data provided by the entity or vendor; (2) data that issubstantiated via a remote interview; or (3) data that is substantiatedby an on-site audit. In particular embodiments, the system is adapted tostore an indication of the confidence level of the answer to eachcompliance question in memory (e.g., along with answer data associatedwith the question in a master questionnaire and/or a compliancequestionnaire for a particular standard or regulation) and toselectively provide this information to a user (e.g., in the form of areport). In this way, the system may provide the user with an indicationof the confidence level that the entity actually complies with thestandard. For example, the system may generate an aggregate confidencescore for an entity's compliance with a particular privacy standardbased on the individual confidence levels associated with each answer toeach question in the compliance questionnaire for that particularprivacy standard.

In particular embodiments, the entity being assessed in the mannerdescribed above may be a vendor. The system may be adapted to allow thevendor to allow other entities to access the vendor's compliance data(e.g., as described herein) and to use such data to independently assesswhether the vendor complies with any of a plurality of privacy standardsand/or regulations. For example, if a particular potential customer of avendor wishes to determine whether the vendor complies with the GDPR,the system may execute a privacy standard compliance module, such asthose described herein, to assess whether the vendor complies with theGDPR. If the system doesn't have answers to all of the questions withina GDPR compliance assessment questionnaire, the system may prompt theuser to provide answers to those questions as discussed above. Thesystem may then optionally save the provided answers for later use bythe vendor, or other potential customers of the vendor.

A potential advantage of various such embodiments is that they may allowa vendor to complete a single master questionnaire (e.g., a masterPrivacy Impact Assessment) that may be used by the vendor and/or aplurality of the vendor's customers to assess the vendor's currentcompliance with various applicable privacy standards and/or regulations.This may alleviate the need for the vendor to provide this data tomultiple parties individually. Another advantage is that suchembodiments may allow an entity, such a vendor, to use a single privacyimpact assessment questionnaire when assessing each of the entity'sbusiness processes.

In various embodiments, the system may execute a privacy standard and/orprivacy regulation compliance module, such as the exemplary PrivacyStandard Compliance Module 5900 shown in FIG. 59. In particularembodiments, the system may execute the Privacy Standard ComplianceModule 5900 in response to user input requesting the evaluation of anentity's (e.g., company, organization, vendor, etc.) compliance with oneor more privacy standards and/or privacy regulations. In executing thePrivacy Standard Compliance Module 5900, at Step 5910, the system mayprompt the user to indicate one or more particular privacy standardsand/or regulations. In various embodiments, the system may ask the userto select one or more standards and/or regulations from a listing ofstandards and/or regulations. Alternatively, or in addition, the systemmay prompt the user to indicate the applicable standards/regulationsusing any suitable means. Further at Step 5910, the system may receiveinput from the user indicating the applicable standards/regulations. Inparticular embodiments, the system may facilitate such prompting forstandards and/or regulations and receipt of indications of applicablestandards and/or regulations by using graphical user interfaces.

At Step 5920, in response to receiving the specified standards and/orregulations, the system may generate or otherwise obtain a particularcompliance questionnaire for each specified standard or regulation. AtStep 5930, the system may generate a master questionnaire of compliancequestions based on the specified standards and/or regulations. Invarious embodiments, the system may generate the ontology mappingquestions in each particular compliance questionnaire to questions inthe master questionnaire and/or to questions in other particularcompliance questionnaires at Step 5930. In particular embodiments, forexample as described above, the system may generate a masterquestionnaire that includes every question from each particularcompliance questionnaire for each specified standard or regulation,while eliminating questions that represent substantially duplicativedata. For example, the system may use pattern matching, machine learningtechniques, or any other means to determine which questions from aparticular privacy standard compliance questionnaire are the same orsimilar to another question in another privacy standard compliancequestionnaire and include just one such question in the masterquestionnaire, reducing the total number of questions presented to theuser.

Further at Step 5930, questions in the master questionnaire may becustomized in any suitable manner. For example, questions may bepresented in natural language form to solicit the correspondinginformation for respective privacy standard compliance questionnaires.Questions may also be presented in a language appropriate for aparticular vendor or user, translated from another language used in oneor more of the privacy standard compliance questionnaires if need be.The system may use machine learning, machine translation, neuralnetworking, and/or any other suitable means of preparing and mappingquestions in a master questionnaire so that the responsive data providedby a user can be used in one or more privacy standard and/or privacyregulation compliance questionnaires.

At Step 5940, the system may present the master questionnaire to theuser and prompt the user for input indicating answers to the compliancequestions in the master questionnaire. Further at Step 5940, the systemmay receive input from the user indicating answers to the compliancequestions in the master questionnaire. Also at Step 5940, the system maydetermine a confidence level for each question, for example, based onthe form of substantiation for the respective question as describedabove. The system may prompt the user to indicate the answers to thecompliance questions using any suitable means. In particularembodiments, the system may facilitate such prompting for answers to thecompliance questions and receipt of indications of answers to thecompliance questions by using graphical user interfaces.

At Step 5950, the system may use the ontology to map the user's answersto the compliance questions in the master questionnaire back to thecompliance questionnaires for each particular privacy standard orprivacy regulation. At Step 5960, the system may to determine, based onthe information mapped from the master questionnaire answers to thecompliance questionnaires for each particular privacy standard orprivacy regulation, whether and/or to what extent the entity is incompliance with the particular privacy standard or privacy regulation.At Step 5970, the system may determine a confidence score for eachparticular privacy standard or privacy regulation compliancedetermination, for example, based on the confidence level for eachquestion in the compliance questionnaire for that particular privacystandard or privacy regulation as described above. At Step 5980, thesystem may present the results of the compliance determinations to theuser. In various embodiments, these determinations may be presented on agraphical user interface or in a report of any form. The system mayalso, or instead, present the results of any compliance determinationand/or associated confidence determination using any suitable means.

Assessing Entity and/or Vendor Readiness to Comply with PrivacyRegulations

Systems and methods according to various embodiments may store, inmemory, an ontology that maps respective data privacy requirements for aparticular jurisdiction or set of regulations (e.g., GDPR, CCPA, Frenchprivacy regulations, German privacy regulations, etc.) to: (1)corresponding data privacy requirements required for compliance with oneor more other particular jurisdictions or sets of regulations; and/or(2) respective corresponding questions within a master questionnaire.For example, the GDPR and the CCPA regulations may each require aparticular privacy policy to be in compliance with the respective set ofregulations. Accordingly, the ontology may map, to each other,corresponding privacy policies listed in the GDPR and the CCPAregulations. By gathering answers to questions in a single masterquestionnaire, the system can map the answers to data privacyrequirements required for compliance with the regulations in variousjurisdictions and/or regions and assess the readiness of an entity to bein compliance with the regulations for such jurisdictions and/orregions.

In various embodiments, an ontology generated and/or stored by thesystem may also, or instead, include respective requirements forsectoral laws (e.g., laws related or applicable to particular businesssectors, such as health, finance, etc., in some instances, in aparticular jurisdiction) to: (1) corresponding requirements required forcompliance in another particular business sector (e.g., in a particularjurisdiction); (2) corresponding data privacy requirements required forcompliance with one or more other particular jurisdictions or sets ofregulations; and/or (3) respective corresponding questions within amaster questionnaire. For example, the healthcare informationregulations (e.g., HIPAA) in a particular jurisdiction may require aparticular privacy policy to be in compliance. Accordingly, the ontologymay map, to each other, corresponding healthcare informationregulations. By gathering answers to questions in a single masterquestionnaire, the system can map the answers to sectoral requirementsrequired for compliance with sectoral regulations (e.g., healthcareinformation regulations, financial information regulations, etc.) forvarious jurisdictions and/or regions and assess the readiness of anentity to be in compliance with the sectoral requirements for suchjurisdictions and/or regions.

The ontology may map each of the respective controls listed in a set ofregulations for a particular region or territory (e.g., GDPR, CCPA,etc.) to a question in a master list of questions that is used to assessthe entity's compliance with the set of regulations for that particularregion or territory. For example, the master questionnaire may include aquestion regarding the use of a particular privacy data control or theimplementation of a particular privacy policy. The system may map thisquestion in the ontology to a requirement of one or more privacyregulations for particular jurisdictions and/or regions. Examples ofsuch a question may include “Does your organization require multi-factorauthentication of employees before they access sensitive data?” and “Doyou prominently display a link to your privacy policy on yourhomepage?”. In a particular example, in response to receiving the answerto this question in the master questionnaire from a user, the system mayuse the answer in conjunction with the ontology to populate the dataassociated with corresponding requirements within particularquestionnaires that are used to assess an entity's readiness to complywith a plurality of privacy regulations for particular jurisdictionsand/or regions, where each particular questionnaire is specific to aparticular set of privacy regulations for a particular jurisdictionand/or region (e.g., GDPR, CCPA, etc.). For example, if the userindicated in the answer to this question in the master questionnairethat the user's organization does not prominently display a link to itsprivacy policy on its homepage, the system may save, in a computermemory using the ontology, an answer corresponding to “entity does notprominently display link to privacy policy on homepage” to thatparticular requirement (or similar requirements that may, for example,be worded differently) as represented in a questionnaire for theparticular privacy regulations for a particular region.

It should be understood that the ontology may vary in complexity basedon the circumstances. In particular embodiments, one or more questionsfrom a master questionnaire (e.g., 1, 2, 3, 4, 5, 10, 25, 50, etc.questions) may each be respectively mapped to one or more correspondingquestions in a plurality of (e.g., any number between 1 and 500, ormore) respective questionnaires for particular sets of regulations forparticular regions or territories. For example, the question aboveregarding displaying a link to a privacy policy on a homepage may bemapped to a respective question in questionnaires for 20 different setsof regulations, each associated with a different territory or region.

The system may include any number and type of questions in a masterquestionnaire and any readiness questionnaire for a particular set ofprivacy regulations for any particular territory or region. The systemmay use the answers to any such questions to determine whether and towhat extent an entity (or a vendor) is ready to comply with a particularset of privacy regulations for any particular territory or region. Notethat any of the particular sets of privacy regulations for anyparticular territory or region described herein may be currently inforce or may be prospective (e.g., planned but not yet in force). Inthis way, the system may determine entity readiness for compliance withvarious sets of privacy regulations that may each have varyingrequirements and may each be currently in force or anticipated to beimplemented in the future. The questions that the system may include ona master questionnaire and/or a readiness questionnaire for a particularterritory or region may include, but are not limited to, controls onaccess to sensitive data, controls on modification and storage ofsensitive data, required disclosures, required security controls ondevices/websites/systems, require policies, required contactinformation, require consent modifications, and any other questionsassociated with any type of control or requirement needed to comply withany set of regulations for any territory, jurisdiction, or region.

FIG. 60 illustrates an exemplary Data Structure 6000 representing aglobal readiness assessment ontology according to particular embodimentsthat may be used for determining an entity's readiness to comply withone or more particular sets of privacy regulations compliance and/or forgathering regulatory compliance information. The Data Structure 6000 mayinclude requirements for each particular set of regulations for aparticular territory or region (and/or for particular sectors in aparticular territory or region), for example, what types of controlsmust be in place, what types of policies are required, physicalrequirements, software requirements, data handling requirements, etc.The Data Structure 6000 may also facilitate the gathering of data for,and the determination of, compliance (or readiness to comply) with anyone or more sets of privacy regulations.

The Global Readiness Master Questionnaire 6010 represents data receivedas answers to a master questionnaire that the system provided to a user.The system may map answers to questions in the master questionnaire tocorresponding answers for one or more other questionnaires. For example,the system may map one or more answers for the Master Questionnaire 6010to one or more answers for the GDPR Readiness Questionnaire 6020 and/orthe CCPA Readiness Questionnaire 6030, as shown in FIG. 60. The systemmay also, or instead, map answers to questions in any particularquestionnaire to corresponding answers for any one or more otherquestionnaires. For example, the system may map one or more questionsfor the GDPR Readiness Questionnaire 6020 to one or more questions forthe CCPA Readiness Questionnaire 6030, as shown in FIG. 60.

For example, the system may map data associated with question 6010A ofthe Global Readiness Master Questionnaire 6010, which may indicatewhether a link to a privacy policy is prominently displayed on theentity's homepage, to question 6020A for the GDPR ReadinessQuestionnaire 6020 and to question 6030C for the CCPA ReadinessQuestionnaire 6030. Also, or instead, the system may map data associatedwith question 6020A for the GDPR Readiness Questionnaire 6020 toquestion 6030C for the CCPA Readiness Questionnaire 6030. The system mayalso, or instead, map data associated with question 6010B of the GlobalReadiness Master Questionnaire 6010, which may provide an indication asto whether a link is provided to allow a data subject to request aconsent modification, to question 6020L for the GDPR ReadinessQuestionnaire 6020, but not to a question in the CCPA ReadinessQuestionnaire 6030. The system may also, or instead, map data associatedwith question 6010Y of the Global Readiness Master Questionnaire 6010 toquestion 6030FH for the CCPA Readiness Questionnaire 6030, but not to aquestion in the GDPR Readiness Questionnaire 6020. In variousembodiments, an ontology may map any one or more questions of anyquestionnaire to any one or more questions in any one or more otherquestionnaires, or to no question in any other questionnaire.

One potential advantage of various embodiments of computer implementedversions of this ontology is that it may allow a user to effectivelycomplete at least a portion of a large number of regulatory readinessquestionnaires by only completing a single, master questionnaire. Invarious embodiments, the system may prompt the user to input answers toeach respective question in the master questionnaire. The system maythen, using the ontology, map the answer to each of the questions toalso be the answer of any corresponding questions in the respectiveregulatory readiness questionnaires for any suitable set of regulations.

In particular embodiments, the system may be configured to dynamicallygenerate and/or edit the current master questionnaire so that the masterquestionnaire includes, for example, at least one question that willprovide the answer for each question within each readiness questionnaireof a plurality of readiness questionnaires for a plurality of respectivesets of regulations (e.g., jurisdictional, sectoral, etc.). For example,if a readiness questionnaire for the GDPR includes a question that isunique to the GDPR (e.g., among the possible or available sets ofregulations for which readiness may be assessed), the masterquestionnaire will include that question if a user indicates that theywould like to assess the entity's compliance with the GDPR. However, ifa user indicates that the entity (or the user) no longer wishes toassess the entity's readiness to comply with the GDPR, the system mayautomatically modify the master questionnaire to remove the question(since the question will no longer be applicable to any relevant set ofregulations). Similarly, if a user later updates the entity's profile toindicate that the entity (or user) again wishes to evaluate the entity'sreadiness to comply with the GDPR, the system may automatically updatethe master questionnaire to include the GDPR-specific question.

In various embodiments, the system may be configured to generate theglobal readiness master questionnaire at any appropriate time. Forexample, in a particular embodiment, the system may prompt the user toindicate the regions and territories for which the user would like tohave the entity evaluated for readiness to comply with the applicableprivacy regulations. In response to receiving this information from theuser, the system may generate a master list of questions that the systemthen uses to assess the readiness of the entity to comply with theapplicable privacy regulations.

After a user provides answers to the questions in a master list, thesystem may use the ontology to map the user's answers to the questionsback to the readiness questionnaires for each specified set ofregulations for each particular region/territory to determine the extentto which the entity is ready to comply with each respective set ofregulations. In various embodiments, the results of this assessment maybe selectively communicated to the user in any suitable way. Forexample, the system may generate and present to the user a reportshowing the degree of readiness (e.g., in percentages) the entity has tocomply with each specified set of privacy regulations.

In particular embodiments, the system may be adapted to not re-presentquestions that the system already has answers for. In such embodiments,the system may only present, to the user, readiness questions forselected sets of privacy regulations that the system doesn't alreadyhave analogous data for (e.g., based on an earlier-answered questionfrom a master list of questions and/or an earlier-answered question froma readiness questionnaire for another set of privacy regulations or anearlier completed readiness questionnaire for this particular set ofprivacy regulations.)

In particular embodiments, the system may be adapted to automaticallydetermine to what extent the entity is ready to comply with one or moreparticular sets of privacy regulations for one or more particularregions or territories (e.g., GDPR, CCPA, etc.), and/or for particularsectors in one or more particular regions or territories, based on dataprovided for the entity in response to various questions within areadiness questionnaire associated with one or more other sets ofprivacy regulations and/or in response to various questions within amaster questionnaire.

In particular embodiments, the entity being assessed in the mannerdescribed above may be a vendor. The system may be adapted to allow thevendor to allow other entities to access the vendor's readinessassessment data (e.g., as described herein) and to use such data toindependently determine the readiness of the vendor to comply with anyof a plurality of set of privacy regulations. For example, if aparticular potential customer of a vendor wishes to determine whetherthe vendor complies with the GDPR, the system may execute a readinessassessment module, such as those described herein, to assess the extentto which the vendor is prepared to comply with the GDPR. If the systemdoesn't have answers to all of the questions within a GDPR readinessassessment questionnaire, the system may prompt the user to provideanswers to those questions as discussed herein. The system may thenoptionally save the provided answers for later use by the vendor orother potential customers of the vendor in future readiness assessments.

A potential advantage of various such embodiments is that they may allowa vendor to complete a single master questionnaire (e.g., a masterglobal readiness questionnaire) that may be used by the vendor and/or aplurality of the vendor's customers to assess the vendor's readiness tocomply with various sets of privacy regulations. This may alleviate theneed for the vendor to provide this data to multiple partiesindividually. Another advantage is that such embodiments may allow anentity, such a vendor, to use a single master questionnaire whenassessing its readiness to comply with multiple sets of privacyregulations.

In various embodiments, the system may execute a global readinessassessment module, such as the exemplary Global Readiness AssessmentModule 6100 shown in FIG. 61. In particular embodiments, the system mayexecute the Global Readiness Assessment Module 6100 in response to userinput requesting the evaluation of an entity's (e.g., company,organization, vendor, etc.) readiness to comply with one or moreparticular sets of privacy regulations for one or more regions orterritories and/or with one or more particular sets of privacyregulations for one or more particular sectors in one or more particularregions or territories. In executing the Global Readiness AssessmentModule 6100, at Step 6110, the system may prompt the user to indicateone or more particular regions, territories, and/or sectors, forexample, in which the entity conducts business or has customers. Invarious embodiments, the system may ask the user to select one or moreregions and/or territories from a map of regions and/or territories orfrom a listing of regions, territories, and/or sectors. Alternatively,or in addition, the system may prompt the user to indicate theapplicable regions, territories, and/or sectors using any suitablemeans. Further at Step 6110, the system may receive input from the userindicating the applicable regions, territories, and/or sectors. Inparticular embodiments, the system may facilitate such prompting forregions, territories, and/or sectors and receipt of indications ofapplicable regions, territories, and/or sectors using one or moregraphical user interfaces.

In various embodiments, the system may allow a user to specify or selectthe particular sets of regulations rather than, or in addition to,selecting regions, territories, and/or sectors. At Step 6120, the systemmay prompt the user to indicate one or more particular sets ofregulations (e.g., GDPR, CCPA, etc.), for example, governing theentity's conduct in various regions, territories, and/or sectors. Invarious embodiments, the system may ask the user to select one or moresets of regulations using a map indicating the regions and/orterritories where such sets of regulations are in force or from alisting of sets of regulations. Alternatively, or in addition, thesystem may prompt the user to indicate the applicable sets ofregulations using any suitable means. Further at Step 6120, the systemmay receive input from the user indicating the applicable sets ofregulations. In particular embodiments, the system may facilitate suchprompting for sets of regulations and receipt of indications ofapplicable sets of regulations using one or more graphical userinterfaces.

At Step 6130, the system may generate a master questionnaire of globalreadiness questions based on the specified regions, territories,sectors, and/or sets of regulations. In various embodiments, the systemmay generate the ontology mapping questions in each particularcompliance questionnaire to questions in the master questionnaire and/orto questions in other particular compliance questionnaires at Step 6130.In particular embodiments, for example as described above, the systemmay generate a master questionnaire that includes every question fromeach particular readiness questionnaire for each specified set ofregulations, while eliminating questions that represent substantiallyduplicative data. For example, the system may use pattern matching,machine learning techniques, or any other means to determine whichquestions from a particular readiness questionnaire for a particular setof regulations are the same or similar to another question in anotherreadiness questionnaire for a different particular set of regulationsand include just one such question in the global readiness masterquestionnaire, reducing the total number of questions presented to theuser.

Further at Step 6130, questions in the global readiness masterquestionnaire may be customized in any suitable manner. For example,questions may be presented in natural language form to solicit thecorresponding information for respective readiness questionnaires.Questions may also be presented in a language appropriate for aparticular user, translated from another language used in one or more ofthe readiness questionnaire if need be. The system may use machinelearning, machine translation, neural networking, and/or any othersuitable means of preparing and mapping questions in a masterquestionnaire so that the responsive data provided by a user can be usedin one or more readiness questionnaires.

At Step 6140, the system may present the global readiness masterquestionnaire to the user and prompt the user for input indicatinganswers to the compliance readiness questions in the masterquestionnaire. Further at Step 6140, the system may receive input fromthe user indicating answers to the questions in the global readinessmaster questionnaire. The system may prompt the user to indicate theanswers to the compliance readiness questions using any suitable means.In particular embodiments, the system may facilitate such prompting foranswers to the compliance readiness questions and receipt of indicationsof answers to the compliance readiness questions using one or moregraphical user interfaces.

At Step 6150, the system may use the ontology to map the user's answersto the compliance readiness questions in the master questionnaire backto the readiness questionnaires for each particular set of privacyregulations. At Step 6160, the system may to determine, based on theinformation mapped from the master questionnaire answers to thereadiness questionnaires for each particular set of privacy regulations,whether and/or to what extent the entity is prepared to comply with eachparticular set of privacy regulations. In particular embodiments, thesystem may determine a percentage of readiness to comply with aparticular set of privacy regulations based on the percentage of answersto questions in a respective questionnaire for that particular set ofprivacy regulations that indicate compliance. For example, if the user'sanswers to 25% of the questions in a questionnaire for a particular setof regulations indicate that the entity complies with the respectiverequirements represented by those questions, the system may determinethat the entity is at 25% readiness to comply with that particular setof regulations. Alternatively, or in addition, the system may employ analgorithm or other means of calculating a readiness level or score(e.g., weighting particular questions) that may be represented in anysuitable manner (e.g., percentage, raw score, relative score, etc.). Thesystem may use any other suitable means of determining an extent of theentity's readiness to comply with the regulations associated with anyparticular region or territory.

At Step 6170, the system may present the results of the compliancereadiness determination to the user. In various embodiments, theseresults may be presented on a graphical user interface or in a report ofany form. The system may also, or instead, present the results of anyreadiness determination using any suitable means.

In various embodiments, the system may be configured to solicit inputregarding territories, regions, sectors, and/or sets of regulations forwhich readiness is to be assessed and/or to present the results of suchreadiness assessments using a graphical user interface. FIG. 62 depictsan exemplary interface 6200 showing a map 6210 of regions andterritories that allows a user to select one or more territories for aglobal readiness assessment (e.g., by the Global Readiness AssessmentModule 6100). The system may indicate on interface 6200 the territoriesselected and the associated regulation for a selected territory. Forexample, territory 6215 may be highlighted or otherwise emphasized as aselected territory, and the system may, in response to selecting theterritory 6215, present a summary 6220 of the privacy regulations thatare applicable to the territory 6215. The system may color code, shade,or otherwise visually indicate which of the territories shown in the map6210 are associated with which regulations. The system may also presenta listing of regulations 6230 that may be applicable to one or moreterritories shown in map 6210. By detecting a user selection of any ofthe regions or territories shown in the map 6210 and/or the listing6230, the system may responsively add the selected regions andterritories to a listing of regions and territories that the system willevaluate for compliance readiness.

FIG. 63 depicts an exemplary interface 6300 showing a listing of privacyregulations 6320. This listing may represent the regulations implicatedwhen a user selected one or more regions or territories, such as oninterface 6200 of FIG. 62. The listing of privacy regulations 6320 mayalso, or instead, allow the user to select additional sets ofregulations for which the entity's readiness is to be evaluated and/ormay allow the user to deselect sets of regulations, thereby removingsuch regulations from those for which the entity's readiness is to beevaluated. The listing of privacy regulations 6320 may be filtered orsorted based on regions and territories, for example using the regionlisting 6310.

As selection of one of the sets of regulations presented in the listingof privacy regulations 6320 may generate another interface (e.g., apop-up window) providing further details regarding that set of privacyregulations, such as interface 6400 shown in FIG. 64. The interface 6400may include a user-interactive listing of the various requirements ofthe selected set of regulations, allowing a user to view the details ofcomplying with that particular set of regulations.

FIG. 65 depicts an exemplary interface 6500 showing the results ofcompliance readiness assessments. The interface 6500 may include a map6510 that may indicate the regions, territories, and/or sectors forwhich the entity's readiness was evaluated. The system may generate alisting of the results of the readiness analysis 6520 for eachapplicable set of regulations. Each entry in the listing 6520 mayinclude specific results for the respective set of regulations. Forexample, the entry 6522 may indicate that the entity is 79% ready tocomply with the EU-U.S. PrivacyShield regulations, while the entry 6524may indicate that the entity is 68% ready to comply with the GDPR. Eachsuch entry may also provide options that a user may select to view moredetails about the results and/or the associated set of regulations. Asnoted above, the system may provide the results of a compliancereadiness assessment in any suitable form.

Generation of an Intelligent Data Breach Response Plan

Because of the large number of regulations that must be followed acrossvarious jurisdictions in order to remain in compliance such regulationsand to properly respond in the event of a data breach or other incident,it can be very difficult for an entity to develop proper response andcompliance plans. In some instances, various requirements andregulations (e.g., jurisdictional, sectoral, standards-based, etc.) maybe in conflict with one another, making the planning and responseprocess even more complex. In particular embodiments, the system may beconfigured to automatically develop a plan for responding to aparticular data breach or other incident based upon various criteriathat take into account requirements and regulations for various regions,territories, and/or sectors. The system may, for example, use one ormore of the follow criteria in developing a response plan for a databreach: (1) the respective disclosure requirements of each regions,territories, and/or sectors (e.g., whether and how quickly theregion/territory/sector requires disclosure of the data breach); (2) howfrequently each region, territory, and/or sector enforces its databreach disclosure requirements; (3) any penalty (e.g., applicable fine)for not properly satisfying the disclosure requirements of each region,territory, and/or sector; (4) how important each region, territory,and/or sector is to the entity's business (e.g., how much business theentity does in the region, territory, and/or sector); and/or (5) anyother suitable factor. Such a plan may be particularly helpful insituations where there are conflicts (e.g., irreconcilable conflicts)between the laws or regulations regarding how and when a particularbreach must be disclosed. For example, where there are conflicts betweenthe regulations of two or more regions, territories, and/or sectors, thesystem may be configured to determine the particular region, territory,or sector for which violation of a regulation is less (or more)impactful and develop a response plan based on that determination.

In various embodiments the system may generate and/or store one or moreontologies in a suitable data structure, for example as describedherein. In exemplary embodiments, such a data structure (or any datastructure configured to organize the data disclosed herein) may include,for example, the requirements of each territory and/or business sector,such as the types of data breaches need to be disclosed in a particularterritory, when and how different types of data breaches need to bedisclosed in a particular territory, etc. In particular embodiments, thedata structure may also include information regarding, for eachparticular region, territory, and/or sector, one or more of: (1) howoften the regulations (e.g., breach-related regulations) of theparticular region, territory, or sector are enforced; (2) the fine(s)for not disclosing a breach as required by the particular region,territory, or sector; (3) how other privacy officers within the entity(or other, similar entities) typically handle data breaches within theparticular region, territory, or sector (e.g., do they routinely complywith a territory's applicable breach disclosure requirements?); and (4)other applicable information that may be useful in developing a decisionas to how to best handle a privacy breach that impacts one or more ofthe regions, territories, and/or sectors in which the entity conductsbusiness.

In various embodiments, the system may enable a user execute aregulatory disclosure compliance module that prompts the user to input,in addition to the information described above, information regardingthe importance of each particular region, territory, or sector to theentity's business and any other business information that may be helpfulin prioritizing efforts in responding to the disclosure requirements ofmultiple different regions, territories, and/or sectors.

After receiving this information, the system may then use any suitablealgorithm to create an ordered list of regions, territories, and/orsectors in which the entity needs to disclose the breach. Particularterritories may be listed, for example, in order of the urgency withwhich the disclosure must be filed in the respective territories (e.g.,based on how soon from the current date the disclosure must be filed ineach territory and/or the importance of the territory to the entity'sbusiness). In particular embodiments, the system may, for example,generate a disclosure urgency score for each territory and order thelist based on the determined respective disclosure urgency scores foreach of the countries.

In various embodiments, the system may communicate this information viaa heat map display of a plurality of territories, where the heat mapvisually indicates (e.g., by displaying the territories in differentrespective colors) which territories require the most immediatedisclosure. In other embodiments, the system may present to a user alisting of affected regions, territories, and/or sectors ordered bytheir relative urgency. In various embodiments, the system is configuredto display detailed information regarding a particular region's,territory's, or sector's disclosure requirements in response to a userselecting the territory on the heat map or from a listing of affectedregions, territories, and/or sectors.

In addition, or instead, the system may be configured to generate a listof recommended steps (e.g., an ordered checklist of steps) that the user(or entity) should complete to satisfy data breach reportingrequirements and recommendations according to the system's logic. Thesystem may present questions to a user soliciting information requiredto satisfy each step and may automatically generate reportingcommunications that may be required by the affected jurisdictions and/orsectors. This may be advantageous because it may allow a user to satisfymultiple different jurisdictions' and/or sectors' respective disclosureobligations, for example, by providing answers to a single questionnaire(e.g., as described herein in regard to the Data Structure 5400). Thismay further be advantageous because it may allow a user to satisfymultiple different jurisdictions' (or different business sectors')respective disclosure obligations according to a particular protocolthat takes into account internal conflict-of-laws logic by completingeach step in the list in the specified order.

It should be understood, based on the discussion above, that a list ofcompliance or disclosure steps may omit one or more steps that arenecessary to comply with the regulations of one or more territoriesregarding the data breach. For example, the system may have determinedthat, since the penalty for non-compliance in a particular territory isbelow a particular monetary threshold, and since the company needs toallocate resources to disclosing the data breach to many otherterritories that have relatively high monetary fines for non-disclosure,it is recommended not to comply, in the particular instance, with thedisclosure regulations of the particular territory.

It should also be understood that the list of steps may be in anysuitable order. For example, steps for complying with a particularjurisdiction's disclosure laws may be listed in consecutive order orintermixed with one or more steps for steps for complying with thedisclosure laws of one or more other jurisdictions. This may be useful,for example, in situations where a particular jurisdiction requires thedisclosure requirement to be completed in two stages, with a first stageto be completed before the due date of a particular action that is duein another jurisdiction, and a second stage to be completed after thedue date of that particular action.

Also, in various embodiments, the system may allow a user to modify thelist of action items (e.g., by deleting certain action items, addingadditional action items, or by reordering the list of action items sothat, for example, at least one of the actions is performed sooner thanit would have been in the original ordered list. In particularembodiments, such manual modifications of the original list may be usedby one or more machine learning modules within the system to adjust thelogic used to present future lists of action items for the entity or forother entities.

In various embodiments, the system may automate one or more of the stepsdescribed herein, for example, as part of a workflow. The system mayautomatically route one or more of the tasks generated to particularrecipients for completion as part of such a workflow. Upon determiningthe particular type of breach or incident and details relating thereto,the system may automatically generate or select a suitable workflow thatmay include such tasks. The system may also use a determined workflow asa template and integrate details of required tasks based on specificinformation related to the particular breach or incident. In particularembodiments, the system may automatically route any of the subtasksand/or any items in any of the checklists described herein to one ormore suitable recipients based on the parameters or details of theassociated incident and or the type of incident.

FIG. 66 depicts a Disclosure Prioritization Module 6600 according to aparticular embodiment, which may be executed, for example, on any of theservers, devices, or computing devices described herein, or on anycombination thereof. The Disclosure Prioritization Module 6600 may alsogenerate, modify, otherwise interoperate with one or more ontologies asdescribed herein. Note that the steps that the Disclosure PrioritizationModule 6600 may perform are described here in an exemplary order. TheDisclosure Prioritization Module 6600 according to various embodimentsmay perform any subset of these steps in any order and/or in conjunctionwith any one or more other functions and activities.

When executing the Disclosure Prioritization Module 6600, the system maybegin, at Step 6610, by generating and presenting an interface to a userprompting the user to provide data breach information. This interfacemay take any form capable of presenting and collecting information froma user. In a particular embodiment, the system may generate a databreach information interface as a GUI presented on one or more computerdisplay devices. The Disclosure Prioritization Module 6600 may use thedata breach information interface to solicit any useful informationabout the data breach. For example, the data breach informationinterface may ask the user to provide an incident name, type of datainvolved (e.g., personal data, particular type of personal data, etc.),an amount of data involved, a number of data subjects affected, a dateon which the breach was discovered (and, in some examples, a time ofdiscovery), the jurisdictions affected, the method used to detect thedata breach (e.g., manually, automatically), a name of user reportingbreach, a sector affected by the breach, and/or any other informationthat may be of use in generating a data breach response plan. The databreach information interface may request information regarding theimportance of each affected territory to the entity's business and/orany other business information that may be helpful in prioritizingefforts in responding to the disclosure requirements of multipledifferent territories. Further at Step 6610, the DisclosurePrioritization Module 6600 may receive the data breach information fromthe user via the interface.

At Step 6620, according to various embodiments, the system may store thereceived data breach information in a data structure that mayincorporate an ontology for future use. For example, after determiningthe affected jurisdictions, the Disclosure Prioritization Module 6600may generate an ontology (e.g., similar to that described in regard tothe Data Structure 5400) that maps respective requirements andrecommendations for compliance with a first privacy law, regulation,standard, and/or policy in a first jurisdiction to correspondingrequirements and recommendations for compliance with one or more otherprivacy laws, regulations, standards and/or policies. The ontologygenerated by the Disclosure Prioritization Module 6600 may also, oralternatively, map each of the requirements and recommendations forcompliance with each privacy law, regulation, standard, and/or policy ineach affected jurisdiction (and, in particular embodiments, sector) to aquestion in a master list of questions in a master questionnaire thatmay be used to request information to address such requirements andrecommendations (e.g., as described above). The DisclosurePrioritization Module 6600 may store the answers received at Step 6610as answers to a master questionnaire and subsequently map those answersto the respective requirements and recommendations for compliance withfor each affected jurisdiction.

At Step 6630, the Disclosure Prioritization Module 6600 may begingenerating a plan for responding to the breach by first determining thedata breach disclosure requirements, if any, for each applicablejurisdiction and/or sector. The Disclosure Prioritization Module 6600may also, at step 6630, determine the consequences, if any, of failuresto address these requirements. The Disclosure Prioritization Module 6600may also, at step 6630, determine one or more recommended (e.g., but notrequired) actions associated with responding to the data breach in eachparticular jurisdiction or sector. For example, for a breach of the typeindicated by the information provided by the user for each affectedjurisdiction, the Disclosure Prioritization Module 6600 may determinewhether disclosing the breach is required, any deadlines associated withdisclosing the breach, any penalties associated with a failure to timelydisclose the breach, the form of notification required in disclosing thebreach, one or more recommended internal notifications (e.g., notify theentity's legal department, notify one or more particular privacyofficers, etc.), and/or any other information that may be specified asrequired or recommended for a territory or region for data breachreporting. Such information may be obtained from one or more datastructures, including one or more data structures having, or associatedwith, one or more ontologies as described herein.

At Step 6640, the Disclosure Prioritization Module 6600 may continuegenerating a plan for responding to the breach by determining one ormore enforcement characteristics for each affected jurisdiction and/orsector. For example, for a breach of the type indicated by the user, theDisclosure Prioritization Module 6600 may determine, for each affectedjurisdiction and/or sector, how often regulations associated with thattype of breach are enforced, how often fines are imposed for notdisclosing a such a breach as required, the potential liability to datasubjects and/or consumers for such a breach, how other privacy officerswithin this and/or one or more other entities typically handle similardata breaches, and/or any other applicable information that may beuseful in developing a data breach response plan. Here again, suchinformation may be obtained from one or more data structures, includingone or more data structures having, or associated with, one or moreontologies as described herein.

At Step 6650, the Disclosure Prioritization Module 6600 may determine orassign a score or grade to each region, territory, and/or sectorimplicated in the data breach based on the information available. Forexample, the Disclosure Prioritization Module 6600 may assign one ormore points or a score for each of several attributes for eachjurisdiction and/or sector. Such attributes may include a businessimportance of a jurisdiction and/or sector, a penalty associated withnot satisfying requirements for a jurisdiction and/or sector, adifficulty of satisfying requirements for a jurisdiction and/or sector,the temporal proximity of a deadline for satisfying requirements for ajurisdiction and/or sector, an availability of a cure period, and/or anyother criteria or attributes that may be associated with a region,territory, and/or sector and its respective data breach responserequirements. The Disclosure Prioritization Module 6600 may determine asum of such points associated with respective attributes for aparticular jurisdiction and/or sector, in some embodiments applying aweight to one or more particular attributes, as a total score for thatjurisdiction or sector. The Disclosure Prioritization Module 6600 mayinstead, or in conjunction, use other any other algorithm or method todetermine a score or other indicator of the importance of eachjurisdiction and/or sector relative to the other affected jurisdictionsand/or sectors at Step 6650.

At Step 6660, the Disclosure Prioritization Module 6600 may rank theaffected jurisdictions and/or sectors based on the scoring determinedfor each jurisdiction and/or sector at Step 6650. The system maygenerate this ranking based solely on scores or grades assigned to eachaffected jurisdiction/sector or may use a combination of factors thatmay or may not include such scoring. In particular embodiments, at Step6660, the Disclosure Prioritization Module 6600 may determine that oneor more jurisdictions and/or sectors have a score, grade, or otherassociated attribute(s) that indicates that the one or morejurisdictions and/or sectors should not be included in a representationof affected jurisdictions at all. For example, the DisclosurePrioritization Module 6600 may determine that, because the penalty fornon-compliance in a particular territory is below a particular monetarythreshold, a penalty score for that jurisdiction may be very low, zero,or even negative (e.g., to reduce the importance of an otherwiseimportant territory due to the very low penalty for non-compliance). TheDisclosure Prioritization Module 6600 may also, or instead, weight apenalty score for each jurisdiction and/or sector so that any very lowor zero penalty removes the jurisdiction from a list of affectedjurisdictions and/or sectors requiring a data breach report (e.g., byusing a penalty score as a multiplier such that a score for thejurisdiction or sector will by zero when other scores for thejurisdiction or sector are multiplied by the penalty score). This mayallow an entity to allocate its limited resources to disclosing the databreach to other territories and/or sectors that may have relativelyhigher monetary fines for non-disclosure by not complying in aparticular jurisdiction or sector where the penalty for non-complianceis relatively inconsequential.

At Step 6670, the Disclosure Prioritization Module 6600 may generate adata representation of the requirements for each jurisdiction and/orsector and/or the ranking of the affected jurisdictions and/or sectors.Note that, at Step 6670, the Disclosure Prioritization Module 6600 maynot present all such data in a single data representation. TheDisclosure Prioritization Module 6600 may generate a ranked list, a heatmap, or other visual representation indicating all, or a subset, of theaffected jurisdictions and/or sectors. The system may allow a user tomanipulate an indicator of each jurisdiction in such a representationand may, in response to detecting such manipulation, present therequirements and/or recommendations for that jurisdiction and/or sector.For example, a user may click or tap on a country represented in a heatmap and the system may, in response, generate another visualrepresentation that shows the data breach response requirements and/orrecommendations for that country. Such requirements and/orrecommendations may be presented in an interactive list format thatallows a user to provide data indicating whether each item in such alist has been performed or to otherwise provide data and inputassociated with the item (e.g., a checklist).

The Disclosure Prioritization Module 6600 may present scores, rankings,data breach response requirements, and/or any other data in any ofvarious formats. For example, the Disclosure Prioritization Module 6600may generate visual interface presented on one or more computer monitorsor display devices indicating scores, rankings, data breach responserequirements, and/or any other data. In addition, or instead, theDisclosure Prioritization Module 6600 may generate one or more printedreports indicating scores, rankings, data breach response requirements,and/or any other data. In addition, or instead, the DisclosurePrioritization Module 6600 may generate one or more audible indicationsof scores, rankings, data breach response requirements, and/or any otherdata. The Disclosure Prioritization Module 6600 may generate and/orprovide any other form of report or provision of scores, rankings, databreach response requirements, and/or any other data, and anycombinations thereof.

FIG. 67 depicts a Data Breach Reporting Module 6700 according to aparticular embodiment, which may be executed, for example, on any of theservers, devices, or computing devices described herein, or on anycombination thereof. The Data Breach Reporting Module 6700 may alsogenerate, modify, otherwise interoperate with one or more ontologies asdescribed herein. Note that the steps that the Data Breach ReportingModule 6700 may perform are described here in an exemplary order. TheData Breach Reporting Module 6700 according to various embodiments mayperform any subset of these steps in any order and/or in conjunctionwith any one or more other functions and activities.

When executing the Data Breach Reporting Module 6700, the system maybegin, at Step 6710, by determining one or more jurisdictions affectedby a data breach. The Data Breach Reporting Module 6700 may determinesuch one or more jurisdictions using a data map, questionnaire, receiveduser input (e.g., as described herein), or any other source ofinformation. At Step 6720, the Data Breach Reporting Module 6700 maydetermine one or more business sectors affected by the data breach. TheData Breach Reporting Module 6700 may determine such one or morebusiness sectors using a data map, questionnaire, received user input(e.g., as described herein), or any other source of information. Theaffected business sector may be important because a jurisdiction mayhave different reporting requirements for data breaches in differentbusiness sectors.

At Step 6730, the Data Breach Reporting Module 6700 may determinewhether the data breach should be reported in each of the one or moreaffected jurisdictions and business sectors. For example, the system maydetermine, at Step 6730, whether to include each particular jurisdictionin an ontology used to generate a master questionnaire solicitinginformation for reporting the data breach. In particular embodiments,the Data Breach Reporting Module 6700 may determine that the entityshould not allocate limited resources to disclosing the data breach in arelatively inconsequential (e.g., based on applicable penalties for notreporting the breach) jurisdiction. For example, using one or moreparticular embodiments described herein, the system may determine that,for a particular territory, the penalty for non-compliance is below aparticular monetary threshold (e.g., based on a penalty score assignedto that jurisdiction of zero or negative as described above). Inresponse, the Data Breach Reporting Module 6700 may determine, at Step6730, to not report the data breach in that particular jurisdiction. Inthis way, the system may avoid requesting user responses to questions ina disclosure or master questionnaire that are specific to thatjurisdiction, thereby saving valuable user and entity resources.

In various embodiments, the Data Breach Reporting Module 6700 mayreceive or obtain a listing of jurisdictions in which reporting shouldbe performed from a module such as the Disclosure Compliance Module 5500or the Disclosure Prioritization Module 6600, either of which may havetaken into account the relative importance of each jurisdiction and maytherefore have already removed one or more affected jurisdictions basedon its analysis of their consequence to the entity.

At Step 6740, the Data Breach Reporting Module 6700 may determine theparticular data breach reporting requirements and recommendations, ifany, for each applicable jurisdiction. For example, the Data BreachReporting Module 6700 may determine that a letter to a regulatory agencythat includes a number of affected data subjects and date of discoveryof the data breach must be generated for a particular jurisdiction. TheData Breach Reporting Module 6700 may also, or instead, determine thatan internal report to the entity's privacy officer that includes theamount of personal data compromised and name of the user handling thedata breach is recommended to be prepared. The Data Breach ReportingModule 6700 may also, or instead, determine that a notification of thedata breach must be sent to affected data subjects or consumers.

Based on the data breach reporting requirements and recommendations, atStep 6750, the Data Breach Reporting Module 6700 may generate anontology that maps respective requirements and recommendations forcompliance with the regulations in a first jurisdiction to correspondingrequirements and recommendations for compliance in one or more otherjurisdictions. The Data Breach Reporting Module 6700 may also, orinstead, generate an ontology at Step 6750 that maps each of therequirements and recommendations for compliance with a particularregulation in a particular jurisdiction to a question in a master listof questions in a master questionnaire that may be used to requestinformation needed to satisfy disclosure requirements in severaljurisdictions.

Once a master questionnaire is generated, at Step 6760, the Data BreachReporting Module 6700 may present the questionnaire to a user promptingthe user to answer questions with information needed to properlydisclose the data breach. For example, the Data Breach Reporting Module6700 may generate an interactive graphical user interface on a computerdisplay device that allows a user to view the questionnaire and submitdata, information, and/or documentation as answers to questions in thequestionnaire. In response to receiving data, information, and/ordocumentation for a question in the master questionnaire at Step 6760,the Data Breach Reporting Module 6700 may use the data, information,and/or documentation and the ontology to populate the data, information,and/or documentation of a corresponding question associated with ajurisdiction and required for compliance with the particular applicableregulations in that jurisdiction. In this way, the Data Breach ReportingModule 6700 may gather the required information for a reporting a databreach in several jurisdictions according to their applicable laws, andregulations using a single master questionnaire rather than a differentquestionnaire per jurisdiction. For example, the Data Breach ReportingModule 6700 may prompt the user to input answers (e.g., number of datasubject affected, date of breach discovery, amount of personal datacompromised, etc.) to each respective question in the masterquestionnaire. The Data Breach Reporting Module 6700 may then map theanswer to each of these questions to the respective answer of anycorresponding questions in the questionnaires for any jurisdiction asappropriate.

At Step 6770, using the data collected and organized using an ontologyat Step 6760, the Data Breach Reporting Module 6700 may generate thecommunications (e.g., a regulatory report or a report to a regulatorybody) required for data breach reporting for a particular jurisdiction.The Data Breach Reporting Module 6700 may format, and/or transmit suchreports based on the requirements of the particular jurisdiction forwhich the report is generated. These communications may be presented toa user for approval or further modification before transmission to aregulatory agency or may be transmitted (e.g., automatically) to aregulatory agency.

FIG. 68 depicts a Regulatory Conflict Resolution Module 6800 accordingto a particular embodiment, which may be executed, for example, on anyof the servers, devices, or computing devices described herein, or onany combination thereof. The Regulatory Conflict Resolution Module 6800may also generate, modify, otherwise interoperate with one or moreontologies as described herein. Note that the steps that the RegulatoryConflict Resolution Module 6800 may perform are described here in anexemplary order. The Regulatory Conflict Resolution Module 6800according to various embodiments may perform any subset of these stepsin any order and/or in conjunction with any one or more other functionsand activities.

When executing the Regulatory Conflict Resolution Module 6800, thesystem may begin, at Step 6810, by determining, receiving, or otherwiseobtaining requirements (e.g., regulations, standards, laws, otherrequirements, etc.) for multiple jurisdictions (e.g., territories,regions, etc.) and/or sectors. For example, the Regulatory ConflictResolution Module 6800 may determine such one or more requirements usinga data map, questionnaire, received user input (e.g., as describedherein), or any other source of information (e.g., as part of collectingdata breach requirements; as part of determining compliance for aparticular jurisdiction or standard, etc.) At Step 6820, the RegulatoryConflict Resolution Module 6800 may determine a requirement for a firstjurisdiction and/or sector conflicts with a similar requirement in asecond jurisdiction and/or sector. For example, the Regulatory ConflictResolution Module 6800 may determine that a first territory requiresthat the entity stores collected personal data for no longer than 90days while a second territory requires that the entity stores collectedpersonal data for at least 90 days. In another example, the RegulatoryConflict Resolution Module 6800 may determine that a first sector in aparticular territory requires that the entity report a data breach in afirst time and manner that is incompatible with the data breach time andmanner reporting requirements for a second sector in that particularterritory. The system may detect any type of conflict and number ofconflicts between regulations, requirements, etc. of any set ofregulations or standards.

At Step 6830, the Regulatory Conflict Resolution Module 6800 maydetermine a risk of non-compliance with each of the regulations that isin conflict with another regulations. For example, the system maydetermine that failure to delete collected personal data after 90 daysin a first territory that requires it incurs only a small yearlymonetary fine if such a failure is detected in an audit that is rarelyperformed. The system may further determine that failure to retaincollected personal data beyond 90 days in a second territory thatrequires it incurs an immediate suspension of the entity's businesslicense and a large monetary fine if such a failure is detected inroutinely performed monthly audits. In this example, the system maydetermine that the risk in the first territory is much less than therisk in the second territory.

In particular embodiments, the system may also, or instead, take intoaccount the business risk involved in non-compliance of conflictingrequirements. For example, the system may determine that the risk ofnon-compliance is much lower in jurisdictions and/or sectors where theentity has few customers (e.g., below a threshold number of customers,such as 10, 50, 100, etc.) and/or much higher in jurisdictions and/orsectors where the entity has many customers (e.g., above a thresholdnumber of customers, such as 100,000, 1,000,000 etc.). In particularembodiments, the system may use a scoring method to determine risk thattakes into account several attributes or factors, each of which may beweighted based on various criteria. For example, at Step 6830, theRegulatory Conflict Resolution Module 6800 may use the scores generatedby the Disclosure Prioritization Module 6600 to determine, at least inpart, the risk of non-compliance with conflicting data breach reportingrequirements. The system may use any other methods and algorithms todetermine risk, including those dedicated to such risk determination.The system may also use any criteria for determining risk, including,but not limited to, a risk of audit, a past history in a particularjurisdiction and/or sector, a history of how an entity has addressedsimilar conflicts in the past, how similar entities have addressedsimilar conflicts, a volume of data processed in a particularjurisdiction and/or sector, types of services offered in a particularjurisdiction and/or sector, business goals in a particular jurisdictionand/or sector, etc.

At Step 6840, the Regulatory Conflict Resolution Module 6800 maydetermine a particular recommended course of action based on the riskdeterminations of Step 6830. For example, the Regulatory ConflictResolution Module 6800 may compare the risks of non-compliancedetermined at Step 6830 and determine to recommend complying with theleast risky requirement. Alternatively, the system may determine toreport the conflict and seek user input regarding the course of actionto be taken.

At Step 6850, the Regulatory Conflict Resolution Module 6800 may providethe recommended course of action to a user, for example, via a graphicaluser interface. Alternatively, the Regulatory Conflict Resolution Module6800 may proceed with the course of action automatically, for example,if configured to do so. Such courses of action may include any activityor function described herein, including those relating to complying withdata breach disclosure requirements or requirements for compliance withany regulation, requirements, rules, standards, etc.

The disclosed systems may generate GUIs that may facilitateimplementation of the disclosed subject matter, examples of which willnow be described in greater detail. FIG. 69 illustrates an exemplaryinterface 6900. A system may generate the interface 6900 on a computingdevice and may present the interface 6900 on a display device. In someembodiments, the system may generate the interface 6900 as a webpagepresented within a web browser. The system may generate the interface6900 in response to detecting the activation of a control indicatingthat a data breach has been discovered.

The interface 6900 may include data entry area 6910 that allow a user toinput details about the data breach. The interface 6900 may allow theentry, in data entry area 6910, of any data breach information describedherein, and any other data breach information. For example, GUI 6900 mayallow the entry of a number of data subjects affected, a volume orquantity of data compromised, a type of personal data compromised, adata breach discovery date and/or time, a data breach occurrence dateand/or time, a data breach reporting date and/or time, a name of thedata breach discovering user or organization, a method of receiving areport of the data breach, a description of the data breach, one or morebusiness sectors affected by the data breach, and/or a name of theparticular data breach. The interface 6900 may also allow submission ofone or more affected jurisdictions, but in other embodimentsjurisdictions may be provided at a different interface, such asinterface 7000 of FIG. 70.

FIG. 70 illustrates an exemplary interface 7000. A system may generatethe interface 7000 on a computing device and may present the interface7000 on a display device. In some embodiments, the system may generatethe interface 7000 as a webpage presented within a web browser. Thesystem may generate the interface 7000 in response to detecting theactivation of a control indicating that a data breach has beendiscovered or in response to detecting an indication that informationhas been received from an earlier presented interface, such as theinterface 6900 of FIG. 69.

The interface 7000 may include a data entry area 7010 that allow a userto input details about one or more jurisdictions and/or sectors affectedby the data breach. The interface 7000 may allow a user to indicate oneor more affected jurisdictions, in the data entry area 7010, byselection of jurisdictions from a map that may include all or a subsetof the jurisdictions in which the entity conducts business. In anotherexample, the interface 7000 may allow a user to indicate one or moreaffected jurisdictions and/or sectors by selecting jurisdictions and/orsectors from a list of jurisdictions and/or sectors in which the entityconducts business. In another example, the interface 7000 may allow auser to indicate one or more affected jurisdictions and/or sectors byentry of the jurisdictions and/or sectors into a text box. In variousother embodiments, any method of collecting affected jurisdiction and/orsector information may be used.

As described herein, once jurisdiction, sector, and/or other data breachinformation has been collected, the system may determine data breachdisclosure and reporting requirement for each affected jurisdictionand/or sector (e.g., as performed by the Disclosure Compliance Module5500, the Disclosure Prioritization Module 6600, the Data BreachReporting Module 6700, and/or in any other suitable manner). The systemmay also determine a score or urgency value for each affectedjurisdiction and may rank the affected jurisdictions and/or sectors, insome embodiments, removing those for which there are no consequentialpenalties for failing to report the data breach. In particularembodiments, the system may also, or instead, remove particularjurisdictions and/or sectors from a ranking for which a regulatoryconflict analysis has determined that those particular jurisdictionsand/or sectors have a lower risk of non-compliance than others that maybe left in the ranking. In various embodiments, the system may presentaffected jurisdictions in a heat map, with various colors and/ortextures used to indicate the relative urgency of data breach reportingfor each jurisdiction. In other embodiments, the system may generate alisting in order of urgency of the affected jurisdictions and/orsectors. In still other embodiments, other methods may be used topresent the affected jurisdictions and/or sectors and their respectivedata breach reporting urgency.

Also as described herein, the system may generate an interactive list ofitems that should be addressed in the event of a data breach. Forexample, the system may generate a listing of actions required by thelaws, regulations, standards, and/or policies associated with arespective jurisdiction and/or sector. The listing may include inputsthat allow a user to “check off” items as they are completed, or tootherwise provide information related to that item. Any such listing maybe ordered based on the urgency, ranking, or other priority as describedherein. For example, the system may place items required to be completedsooner and/or subject to a higher non-compliance penalty than otheritems earlier in a list, for example, based on a score assigned to eachitem and/or to its respective jurisdiction or sector. In anotherexample, the system may place items that do not have an associated cureperiod earlier in a list, for example, based on a score assigned to eachitem and/or to its respective jurisdiction or sector.

In the example shown in FIG. 71, the system may generate an exemplaryinterface 7100 that may include a heat map 7110. The heat map 7110 mayindicate various jurisdictions, at least a subset of which may includeone or more jurisdictions affected by the data breach. The system maycolor code and/or generate texture for each affected jurisdiction asshown in the heat map 7110. The interface 7100 may include legend 7120that may indicate the values or descriptions of the urgency associatedwith each color shown in the heat map 7110. The system may also, orinstead, use coloring and/or texture to indicate the affected businesssector in each affected jurisdiction.

The interface 7100 may also include one or more listings of tasks to beperformed and/or recommended next steps, each of which may be presentedin order of importance or urgency. For example, the listing 7130 mayprovide a list of steps that are recommended and/or required to beperformed in response to a data breach. The listing 7130 may includeitems that are generally required and/or applicable to more than oneaffected jurisdiction and/or sectors (e.g., instead of items associatedwith only one jurisdiction). The listing 7130 may include items orderedby urgency, which the system may have determined based on a score orother value assigned to each item. The system may provide a check boxfor each of the items in the listing 7130. Upon completion of an item, auser may select the check box for that item. In various embodiments, thesystem may remove that item from the listing 7130 and/or make a recordof item completion and no longer present that item to a user as part ofa list of incomplete data breach response activities. The system mayalso provide a mechanism allowing the assignment of each item in thelisting 7130 to a particular user or to an organization. Upon assignmentto a particular user or organization, the system may remove that itemfrom the listing 7130 and/or make a record of item completion and nolonger present that item to a user as part of a list of incomplete databreach response activities. Alternatively, the system may leave anyassigned items on the listing 7130 until the assigned user ororganization provides an indication or confirmation that the item hasbeen completed.

Each of the items in the listing 7130 may have one or more associatedtasks to be performed. For example, for the highlighted first item inthe listing 7130, the system may generate a listing of tasks associatedwith the item may be provided in the subtask listing 7140. The subtasklisting 7140 may include tasks ordered by urgency, which, as for itemsin the listing 7130, the system may have determined based on a score orother value assigned to each task. The system may provide a check boxfor each of the tasks in the subtask listing 7140. Upon completion of atask, a user may select the check box for that task. In variousembodiments, the system may remove that task from the subtask listing7140 and/or make a record of task completion and no longer present thattask to a user as part of a list of incomplete data breach responseactivities. The system may also provide a mechanism allowing theassignment of each task in the subtask listing 7140 to a particular useror to an organization. Upon assignment to a particular user ororganization, the system may remove that task from the subtask listing7140 and/or make a record of task completion and no longer present thattask to a user as part of a list of incomplete data breach responseactivities. Alternatively, the system may leave any assigned tasks onthe subtask listing 7140 until the assigned user or organizationprovides an indication or confirmation that the task has been completed.

As described herein, the system may be configured to display detailedinformation regarding a particular jurisdiction's disclosurerequirements in response to a user selecting the jurisdiction on a heatmap or from a listing of affected jurisdictions. In the example shown inFIG. 72, the system may generate an exemplary interface 7200 that mayinclude a heat map 7210. The heat map 7210 may indicate variousjurisdictions (e.g., geographical territories, regions), at least asubset of which may include one or more jurisdictions affected by thedata breach. The system may color code and/or add texture to eachaffected jurisdiction as shown in the heat map 7210. Upon selection ofan affected jurisdiction (the United Kingdom in the particular exampleof FIG. 72), the interface 7200 may generate data breach responsedetails 7220 that may provide details about the recommended and/orrequired data breach response actions for the selected jurisdiction.

The interface 7200 may also include listings of tasks to be performedand/or recommended next steps, each of which may be presented in orderof importance or urgency. For example, the listing 7230 may provide alist of steps recommended and/or required to be performed in response toa data breach. The listing 7230 may include items that are particularlyrequired and/or applicable to the selected affected jurisdiction orsector (the United Kingdom in the particular example of FIG. 72).Alternatively, the listing 7230 may include items that are generallyrequired and/or applicable to more than one affected jurisdiction orsector, while data breach response details 7220 may provide detailsabout the recommended and/or required data breach response actions forthe selected jurisdiction or sector (e.g., in the particular example ofFIG. 72, the listing 7230 may show items that are generally requiredand/or applicable to multiple jurisdictions and/or sectors, while databreach response details 7220 may show items particularly relevant to theUnited Kingdom). The listing 7230 may include items ordered by urgency,which the system may have determined based on a score or other valueassigned to each item. The system may provide a check box for each ofthe items in the listing 7230. Upon completion of an item, a user mayselect the check box for that item. In various embodiments, the systemmay remove that item from the listing 7230 and/or make a record of itemcompletion and no longer present that item to a user as part of a listof incomplete data breach response activities. The system may alsoprovide a mechanism allowing the assignment of each item in the listing7230 to a particular user or to an organization. Upon assignment to aparticular user or organization, the system may remove that item fromthe listing 7230 and/or make a record of item completion and no longerpresent that item to a user as part of a list of incomplete data breachresponse activities. Alternatively, the system may leave any assigneditems on the listing 7230 until the assigned user or organizationprovides an indication or confirmation that the item has been completed.

The system may determine one or more associated tasks to be performedfor each of the items in the listing 7230. For example, for thehighlighted first item in the listing 7230, a listing of tasksassociated with that particular item may be provided in the subtasklisting 7240. The subtask listing 7240 may include tasks ordered byurgency, which, as for items in the listing 7230, the system may havedetermined based on a score or other value assigned to each task. Thesystem may provide a check box for each of the tasks in the subtasklisting 7240. Upon completion of a task, a user may select the check boxfor that task. In various embodiments, the system may remove that taskfrom the subtask listing 7240 and/or make a record of task completionand no longer present that task to a user as part of a list ofincomplete data breach response activities. The system may also providea mechanism allowing the assignment of each task in the subtask listing7240 to a particular user or organization. Upon assignment to aparticular user or organization, the system may remove that task fromthe subtask listing 7240 and/or make a record of task completion and nolonger present that item to a user as part of a list of incomplete databreach response activities. Alternatively, the system may leave anyassigned tasks on the subtask listing 7240 until the assigned user ororganization provides an indication or confirmation that the task hasbeen completed.

In the example shown in FIG. 73, the system may generate an exemplaryinterface 7300 that may include a listing 7310 of one or more itemsrequired to be performed in response to a data breach. The listing 7310may include items 7320, 7330, and 7340 that may be ordered by urgency orotherwise ranked based on a score or other value determined by thesystem and assigned to each item, for example, as described herein. Forexample, the item 7320 may have the highest urgency score, and thereforeis listed first, followed by the item 7330, which may have the secondhighest urgency score, and then followed by the item 7340, which mayhave the third highest urgency score. Each of the items 7320, 7330, and7340 may include a summary or a detailed description of its requirementsand associated characteristics, such as the jurisdiction and/or sectorto which the item corresponds. Items that may typically be required forcompliance may be removed from a list such as the listing 7310 due toconflict-of-laws decisions made earlier, as described above.

The system may present a check box for each of the items 7320, 7330, and7340 in the interface 7300. Upon completion of an item, a user mayselect the check box for that item. In various embodiments, the systemmay remove that item from its listing of required items and/or make arecord of item completion and no longer present that item to a user aspart of a list of incomplete data breach response activities. The systemmay also provide a mechanism allowing the assignment of each of theitems 7320, 7330, and 7340 in interface 7300 to a particular user ororganization. Upon assignment to a particular user or organization, thesystem may remove that item from the listing 7310 and/or make a recordof item completion and no longer present that item to a user as part ofa list of incomplete data breach response activities. Alternatively, thesystem may leave any assigned items on the listing 7310 until theassigned user or organization provides an indication or confirmationthat the item has been completed.

As described herein, the system may determine which affectedjurisdictions and/or sectors require reporting of data breaches. Thesystem may use information collected via a master questionnaire topopulate a data structure that uses an ontology to map answers toquestions in the master questionnaire to questions associated withparticular jurisdictions and/or sectors. In the example shown in FIG.74, an exemplary interface 7400 may include questions 7410 from a masterquestionnaire that allow a user to input answers to each question in themaster questionnaire. The interface 7400 may allow the entry, viaquestions 7410 from the master questionnaire, of any data breachinformation described herein or otherwise and/or that may be needed tocomplete the data breach reporting requirements for one or morejurisdictions. For example, questions 7410 may include questionssoliciting a number of data subjects affected, a volume or quantity ofdata compromised, a type of personal data compromised, a data breachdiscovery date and/or time, a data breach occurrence date and/or time, adata breach reporting date and/or time, a method of receiving a reportof the data breach, a business sector affected by the breach, and/or adescription of the data breach. In response to receiving the data breachinformation as answers to the questions 7410, the system may map theanswers to respective questions in particular questionnaires forparticular jurisdictions as described herein.

In various embodiments, the system may present questions in a masterquestionnaire, such questions 7410 from a master questionnaire, in anorder that corresponds to the order of such questions in correspondingreporting documents or other communications. This may make it easier fora user to prepare and finalize the reporting communications ordocumentation for each jurisdiction and/or sector. Alternatively, or inaddition, the system may present questions in an order that allows thesystem to take into account internal conflict-of-laws logic byaddressing such conflicts in turn.

To further illustrate the disclosed embodiments, an example will now beprovided. This example is only intended to further illustrate exemplaryaspects of the various embodiments and is not intended to provide anylimitations to any embodiments of the disclosed subject matter.

In an example, a business may determine that a breach of personal dataor personal information has occurred. The business may determine that500,000 user accounts having personal data or personal information forusers in the U.S. and Canada have been accessed by an unauthorizedsystem. Each such user account may include a user's first name and lastname and at least one credit card number. In response, an employee ofthe business may operate a system, such as those described herein, tointeract with one or more interfaces (e.g., as described in regard tointerface 6900, interface 7000, etc.) to provide incident information,such as the type of data compromised (here, names and credit cardnumbers), the affected jurisdictions (in this example, the U.S. andCanada), a number of compromised accounts (in this example, 500,000),and a date of discovery of the breach. The employee may provide anyother useful information to the system. The system may then process theinformation (e.g., as performed by the Disclosure Compliance Module5500, the Disclosure Prioritization Module 6600, the Data BreachReporting Module 6700, and/or in any other suitable manner) and presentthe next steps to the employee regarding reporting requirements, forexample, in a prioritized listing (e.g., as described in regard tointerfaces 7100, 7200, 7300, 7400). For example, the system may providea listing that includes supplying a notification to the business's legaldepartment, supplying a notification to a California regulatory agency,and supplying a notification to a Canadian regulatory agency, in thatorder. The system may also include penalties associated with each step,such as the potential civil penalties for failure to provide thenotifications to the California regulatory agency and the Canadianregulatory agency. Alternatively, the system may substantiallyautomatically take actions to report or otherwise address the breach asdescribed herein. As the user completes the steps provided by thesystem, the user may provide information via an interface (e.g., asdescribed in regard to interfaces 7100, 7200, 7300, 7400) that thesystem may use to track the completion of the steps. The system maythen, automatically or upon demand, update the listing of steps toremove completed steps and/or add additional steps based on newlyreceived information.

Conclusion

Although embodiments above are described in reference to various systemsand methods for assessing the risk associated with particular vendors,it should be understood that any applicable concept described hereincould be done with entities other than vendors—for example businesspartners other than vendors, tenants in the context of landlord/tenantrelationships, etc.

Also, although embodiments above are described in reference to varioussystems and methods for creating and managing data flows related toindividual privacy campaigns, it should be understood that variousaspects of the system described above may be applicable to otherprivacy-related systems, or to other types of systems, in general. Forexample, the functionality described above for obtaining the answers tovarious questions (e.g., assigning individual questions or sections ofquestions to multiple different users, facilitating collaborationbetween the users as they complete the questions, automaticallyreminding users to complete their assigned questions, and other aspectsof the systems and methods described above) may be used within thecontext of Privacy Impact Assessments (e.g., in having users answercertain questions to determine whether a certain project complies withan organization's privacy policies).

While this specification contains many specific embodiment details,these should not be construed as limitations on the scope of anyinvention or of what may be claimed, but rather as descriptions offeatures that may be specific to particular embodiments of particularinventions. Certain features that are described in this specification inthe context of separate embodiments may also be implemented incombination in a single embodiment. Conversely, various features thatare described in the context of a single embodiment may also beimplemented in multiple embodiments separately or in any suitablesub-combination. Moreover, although features may be described above asacting in certain combinations and even initially claimed as such, oneor more features from a claimed combination may in some cases be excisedfrom the combination, and the claimed combination may be directed to asub-combination or variation of a sub-combination.

Similarly, while operations are depicted in the drawings in a particularorder, this should not be understood as requiring that such operationsbe performed in the particular order shown or in sequential order, orthat all illustrated operations be performed, to achieve desirableresults. In certain circumstances, multitasking and parallel processingmay be advantageous. Moreover, the separation of various systemcomponents in the embodiments described above should not be understoodas requiring such separation in all embodiments, and it should beunderstood that the described program components and systems maygenerally be integrated together in a single software product orpackaged into multiple software products.

Many modifications and other embodiments of the invention will come tomind to one skilled in the art to which this invention pertains havingthe benefit of the teachings presented in the foregoing descriptions andthe associated drawings. While examples discussed above cover the use ofvarious embodiments in the context of operationalizing privacycompliance and assessing risk of privacy campaigns, various embodimentsmay be used in any other suitable context. Therefore, it is to beunderstood that the invention is not to be limited to the specificembodiments disclosed and that modifications and other embodiments areintended to be included within the scope of the appended claims.Although specific terms are employed herein, they are used in a genericand descriptive sense only and not for the purposes of limitation.

What is claimed is:
 1. A method comprising: determining, by computinghardware, data breach response requirements for each affectedjurisdiction for a data breach; obtaining, by the computing hardware,data breach response prioritization data; generating, by the computinghardware and based on evaluating the data breach response requirementsagainst the data breach response prioritization data, a graphical userinterface by configuring a first navigation element on the graphicaluser interface and excluding a second navigation element from thegraphical user interface, wherein: the first navigation element isconfigured for navigating to a first display element that presents afirst data breach response requirement, and the second navigationelement is configured for navigating to a second display element thatpresents a second data breach response requirement; transmitting, by thecomputing hardware, a first instruction to a user device to present thegraphical user interface on the user device; detecting, by the computinghardware, a selection of the first navigation element; and in responseto detecting the selection of the first navigation element,transmitting, by the computing hardware, a second instruction to theuser device causing the user device to retrieve and present the firstdisplay element on the user device.
 2. The method of claim 1, wherein:generating the graphical user interface further comprises: configuring athird navigation element on the graphical user interface, wherein thethird navigation element is configured for navigating to a third displayelement that presents a third data breach response requirement; andpositioning the first navigation element and the third navigationelement on the graphical user interface based on evaluating the databreach response requirements against the data breach responseprioritization data.
 3. The method of claim 2, further comprising:determining, by the computing hardware, that the third data breachresponse requirement has been completed; and responsive to determiningthat the third data breach response requirement has been completed,modifying, by the computing hardware, the graphical user interface toexclude the third navigation element.
 4. The method of claim 1, wherein:the method further comprises, obtaining, by the computing hardware, databreach requirement enforcement data for each affected jurisdiction; andgenerating the graphical user interface is further based on evaluatingthe data breach response requirements against the data breachrequirement enforcement data for each affected jurisdiction.
 5. Themethod of claim 1, wherein the data breach response prioritization datacomprises: a ranking of each of the affected jurisdictions; and at leastone of: penalty data for each respective data breach responserequirement, and enforcement frequency data for each of the affectedjurisdictions.
 6. The method of claim 1, wherein: the method furthercomprises determining, by the computing hardware, a respectiveprioritization score for each affected jurisdiction based on at leastone of penalty data for each affected jurisdiction, deadline data foreach affected jurisdiction, and a number of data subjects affected bythe data breach in each affected jurisdiction; and generating thegraphical user interface is further based on the respectiveprioritization score for each affected jurisdiction.
 7. The method ofclaim 6, further comprising modifying each respective prioritizationscore based on a user-provided weighting factor for each affectedjurisdiction.
 8. A system comprising: a non-transitory computer-readablemedium storing instructions; and processing hardware communicativelycoupled to the non-transitory computer-readable medium, wherein theprocessing hardware is configured to execute the instructions andthereby perform operations comprising: identifying data breach data andaffected jurisdictions for a data breach; determining data breachresponse requirements for each of the affected jurisdictions based onthe data breach data; obtaining data breach response prioritizationdata; generating a response plan for the data breach by evaluating thedata breach response requirements against the data breach responseprioritization data; generating, based on the response plan, a graphicaluser interface by configuring a first set of navigation elements on thegraphical user interface and excluding a second set of navigationelements from the graphical user interface, wherein: each respectivenavigation element of the first set of navigation elements is configuredfor navigating to a different respective display element that presents afirst different respective data breach response requirement, and eachrespective navigation element of the second set of navigation elementsis configured for navigating to a different respective display elementthat presents a second different respective data breach responserequirement; transmitting a first instruction to a user device topresent the graphical user interface on the user device; detecting aselection of a first navigation element of the first set of navigationelements; and in response to detecting the selection of the firstnavigation element, transmitting a second instruction to the user devicecausing the user device to retrieve and present the respective displayelement for the first navigation element on the user device.
 9. Thesystem of claim 8, wherein the processing hardware is further configuredto perform operations comprising: completing a first data breachresponse requirement; and responsive to performing the first data breachresponse requirement, modifying the graphical user interface byexcluding a second navigation element from the first set of navigationelements, wherein the second navigation element is configured fornavigating to a second display element that presents the first databreach response requirement.
 10. The system of claim 8, wherein: a thirdnavigation element of the first set of navigation elements displays acompletion status of a second data breach response requirement; and themethod further comprises: causing performance of the second data breachresponse requirement; and responsive to causing the performance of thesecond data breach response requirement, modifying, by the computinghardware, the third navigation element to indicate the completion statusof the second data breach response requirement to reflect theperformance of the second data breach response requirement.
 11. Thesystem of claim 8, wherein: the processing hardware is furtherconfigured to perform operations comprising, obtaining data breachrequirement enforcement data for each of the affected jurisdictions; andgenerating the response plan for the data breach is further based onevaluating the data breach response requirements against the data breachrequirement enforcement data for each of the affected jurisdictions. 12.The system of claim 8, wherein the data breach response prioritizationdata comprises a user-provided prioritization of each of the affectedjurisdictions.
 13. The system of claim 8, wherein the response plancomprises an ordered listing of at least one of the data breach responserequirements.
 14. The system of claim 8, wherein configuring the firstset of navigation elements on the graphical user interface comprisesconfiguring each respective navigation element of the first set ofnavigation elements according to the response plan.
 15. A systemcomprising: a non-transitory computer-readable medium storinginstructions; and processing hardware communicatively coupled to thenon-transitory computer-readable medium, wherein the processing hardwareis configured to execute the instructions and thereby perform operationscomprising: identifying data breach data and affected jurisdictions fora data breach; determining data breach response requirements for each ofthe affected jurisdictions based on the data breach data; obtaining databreach response prioritization data; generating a response plan for thedata breach by evaluating the data breach response requirements againstthe data breach response prioritization data; and causing performance ofone of the data breach response requirements according to the responseplan.
 16. The system of claim 15, wherein the processing hardware isfurther configured to perform operations comprising performing each ofthe data breach response requirements according to the response plan.17. The system of claim 15, wherein: a first response requirement for afirst jurisdiction conflicts with a second response requirement for asecond jurisdiction; and generating the response plan comprisesevaluating the first response requirement and the second responserequirement against the data breach response prioritization data todetermine which of the first response requirement and the secondresponse requirement to include in the response plan.
 18. The system ofclaim 17, wherein the processing hardware is further configured toperform operations comprising: generating, based on the response plan, agraphical user interface by configuring a first navigation element onthe graphical user interface and excluding a second navigation elementfrom the graphical user interface, wherein: the first navigation elementis configured for navigating to a first display element that presentsthe first response requirement, and the second navigation element isconfigured for navigating to a second display element that presents thesecond response requirement; transmitting a first instruction to a userdevice to present the graphical user interface on the user device;detecting a selection of the first navigation element; and in responseto detecting the selection of the first navigation element, transmittinga second instruction to the user device causing the user device toretrieve and present the first display element on the user device. 19.The system of claim 18, wherein: the first navigation element displays acompletion status of the first response requirement; and the processinghardware is further configured to perform operations comprising: causingperformance of the first response requirement; and responsive to causingthe performance of the first response requirement, modifying, by thecomputing hardware, the first navigation element to indicate thecompletion status of the first response requirement to reflect theperformance of the first response requirement.
 20. The system of claim15, wherein: the processing hardware is further configured to performoperations comprising determining, by the computing hardware, arespective prioritization score for each of the affected jurisdictionsbased on at least one of penalty data for each of the affectedjurisdictions, deadline data for each of the affected jurisdictions, anda number of data subjects affected by the data breach in each of theaffected jurisdictions; and generating the response plan is furtherbased on the respective prioritization score for each of the affectedjurisdictions.